Terms and Conditions - Otet Markets

Otetmarkets.com is the official website of the Otet Group:

1. Otet Group Ltd., a company duly incorporated in Saint Lucia, registration No. 2023-00595, being a brokerage company,

2. Otet Group LTD, a company duly incorporated in the Comoros Union (Mwali), registration No. HY00523012, holding a valid Brokerage License

(each hereinafter referred to as the “Company”).

Your access to and use of this website is subject to these terms and conditions, our Client Agreement, and any notices, disclaimers, statements, policies, as well as other documents contained on this website (collectively referred to as the “Terms and Conditions”).

By using this website, you agree to be subject to the Terms and Conditions.

The Terms and Conditions constitute a public offer with standard conditions. This offer is considered accepted when you perform actions indicating your consent, such as accessing, using our website, our services. By doing so, you completely agree with the Terms and Conditions.

The information contained on this website is not guaranteed, is strictly for information purposes only and subject to change without notice.

Although the information and materials allocated on our website are based upon information that the Company considers reliable and endeavours to keep current, it does not warrant that the information or materials are current or accurate at all times and it should not be relied upon as such (safe for the Terms and Conditions remaining actual and complete). To the extent permitted by law, the Company does not accept any responsibility arising in any way from errors in, or omissions from, this information and materials.

The securities, other trading assets, financial instruments, services described on the website vary from time to time and may not always be available or may be restricted.

The content should not be construed in any way as a recommendation or investment advice.

If you disagree with any part of the Terms and Conditions, you should immediately cease using our website. By accessing or using our services, you confirm that you were provided with access to the Terms and Conditions before their acceptance, and you had sufficient time to review it carefully and copy them if needed.

You may only use our website and services, if you are not legally prohibited from receiving our services under the laws where you are residing, registered.

1. Chat and Instant Messaging

You are advised that Chat and Instant Messaging conversations are recorded and may be used for compliance, training and other purposes specified in the Terms and Conditions.

Conversations on Chat or through Instant Messaging is for your general information only and the Company is not soliciting any action based upon it. It does not take into account the particular investment objectives, financial situation or needs of individual clients. Before acting on any information in any Chat or Instant Message, you should consider whether it is suitable for your particular circumstances and, if necessary, seek professional advice.

2. Monitoring

Your use of this website may be monitored by the Company, and the outcoming information may be used by the Company for its internal business purposes and other operating and regulatory processes.

For details of your personal data handling please refer to our Privacy Policy.

3. General Advice & Suitability

The information and materials on this website have been prepared for informational purposes only (safe for the Terms and Conditions remaining actual and complete) without regard to any particular user’s investment objectives, financial situation, or means, and the Company is not soliciting any action based upon it.

Provision of the information and materials on this website does not constitute nor should it be considered a recommendation that you enter into a particular transaction, nor a representation that any service described on this website is suitable or appropriate for you.

You should neither construe any of the material contained in the website as business, financial, investment, hedging, trading, legal, regulatory, tax, accounting or other advice, nor make its content the primary basis for any investment decisions made by or on behalf of you.

You are advised to consult your personal financial adviser, attorney, and tax, and accounting and other advisors concerning any contemplated transactions.

4. Risk

Many of the securities, other trading assets, financial instruments described on this website involve significant risks, and you should not enter into any transactions unless you have fully understood all such risks and have independently determined that such transactions are appropriate for you.

Any discussion of the risks contained herein with respect to any securities, other trading assets, financial instruments should not be considered to be a disclosure of all risks or complete discussion of the risks which are mentioned.

The company’s Risk Disclosure Statement contains the risks warning and should be reviewed prior to conducting transactions.

5. Jurisdiction Notice

Any our material must not to be construed as a recommendation, or an offer to acquire, buy or sell, or the solicitation of an offer to acquire, buy or sell any securities, other trading assets, financial instrument, or to participate in any particular trading strategy in any jurisdiction in which such an offer or solicitation, or trading strategy would be illegal.

There are legal requirements in various countries which may restrict the information which we are lawfully permitted to provide to you.

You must be over 18 years of age to use the services of the Company.

6. Copyright

All content available on our website, is owned, controlled, or operated by us. Such content includes, but is not limited to, text, images, logos, trademarks, graphics, designs, software, data compilations, audio, video, page layout, and any other form of information that can be stored in a computer or device and is displaying on or forms a part of this website.

By accessing or using our website you acknowledge and agree that such content is protected by copyright, trademarks, and any other intellectual property rights. Nothing on the website must be interpreted as granting by implication or otherwise, any license or right to use any logo, trademark, or service mark displayed on our website without the respective prior written consent.

Except where necessary in order to view the information on this website on your browser, or as permitted under the applicable laws or the Terms and Conditions, no information or content on this website may be reproduced, adapted, uploaded to a third party, linked to, framed, performed in public, distributed or transmitted in any form by any process without our specific written consent.

You acknowledge that the Company shall be entitled to require you to remove any link from another website to this website which you allocated without obtaining the Company’s prior written consent.

Any third-party intellectual property used by us in the content of our website should not be interpreted as meaning that the third-party owner sponsors, endorses or is in any way affiliated with us or with our business, nor that they make any representation regarding the advisability of using our products.

7. Third Party Content

This website may contain information and materials produced by third parties or links to other websites. Such materials and websites are provided by third parties and are not under the Company’s direct control.

The Company provides such links solely as a convenience to you. Accordingly, the Company makes no representations concerning the content of these sites. The fact that the Company has provided a link to these sites does not constitute an endorsement, authorization, sponsorship, or affiliation by the Company with respect to these sites, their owners and providers.

We are not responsible for any hyperlinked Internet sites through this website, and are not responsible for any losses incurred in connection with those sites.

8. Banned Activities

You are strictly prohibited from using our website and Services if you engage in any of the following behaviors, whether intentionally or unintentionally, including but not limited to:

1) Acting in a way that damages, or could damage, our website, including but not limited to the security and safety features, or interfering with other users’ access to our website;

2) Engaging in activities related to money laundering, drug trafficking, terrorism, fraud, criminal acts, or any other illegal activities;

3) Infringement upon any intellectual property rights;

4) In any manner that damage or may damage our good name and repute;

5) Insulting, harassing or using offensive or discriminatory language against other users, our representatives;

6) Participating in any activities that are harmful, illegal, abusive, or violate the Terms and Conditions or any applicable laws or regulations.

9. The Company’s liability

The Company is not liable for any damages including, without limitation, damage to your computer or computer system or settings, loss of data, revenue or profits, which you may suffer arising out of your use, delay in using, or inability to access this website, or in any other way connected with this website, including from the downloading of any software from this website. The Company disclaims any representation or warranty that the website or materials will meet your requirement or that the website or any software will be uninterrupted, secure or free from errors or viruses.

Any services, data, tools on the website are provided “as is” and on an “as available” basis. We reserve the right to update the information on our website at our discretion. To the maximum extent permitted by the law, we provide no expressed or implied warranties of accuracy, compatibility, reliability, wholeness, integrity, usefulness of our website. Any reliance you place on such information is therefore strictly at your own risk.

We will not be held liable to you in respect of any losses in connection with our website, arising out of force majeure events.

To the maximum extent permitted by law, we accept no liability to you in connection with the website for any of the following, including but not limited to:

1) Any business or commercial losses, including loss of profits, income, revenue, anticipated savings, contracts, or business opportunities;

2) Any special, direct or indirect, incidental, punitive or consequential loss or damage;

3) Any errors, delays, disruptions, failures, non-availability, or suspensions in the functionality of our website;

4) Your action or inaction on our website, any deals made through our website;

5) Loss or corruption of any data, database or software;

6) Any other losses or damage that may be incurred through using this website content.

10. Amendment Part of the Otet Markets Client Agreement and Terms & Conditions

Amendment to Clause 14.3 · New Clauses 23 to 28 — Prohibited Trading Practices · Account, Transfer & Withdrawal Review · Risk-Management Measures · Account Monitoring · Order Execution · Promotional Credit Administration

This amendment forms an integral part of the Otet Markets Client Agreement and Terms & Conditions. It amends clause 14.3 as set out in Part 1, and inserts new clauses 23 to 28 following clause 22 (Trading Abuse, Fair Trading and Compliance) as set out in Part 2. By continuing to hold an account, transferring funds, or placing any order after the effective date, the Client agrees to be bound by the provisions below. Capitalised terms have the meaning given in the Terms and Definitions document, except where defined in this amendment.

Part 1 — Amendment to Clause 14.3 (Obligations of the Client)

1.1. In clause 14.3 of the Client Agreement, the following provision is deleted in its entirety:

“in the event there is a negative balance on his trading account, Client is entitled to depositing his own funds to bring account to zero within 10 (ten) calendar days on Company’s requirement.”

1.2. and is replaced with the following:

“in the event there is a negative balance on the Client’s trading account, the Client shall, on the Company’s requirement, deposit sufficient funds to restore the account balance to zero within 10 (ten) calendar days of that requirement. This obligation applies irrespective of the cause of the negative balance, save where the negative balance arises from a manifest error, technical failure, or incorrect calculation attributable to the Company.”

1.3. The remaining provisions of clause 14.3 are unaffected by this Part 1.

1.4. For the avoidance of doubt, the obligation in clause 14.3 as amended is an obligation of the Client, and is not a discretion, option, or entitlement exercisable at the Client’s election. Where the account forms part of a coordinated chain, clause 23.6.3 applies to that obligation.

Part 2 — New Clauses 23 to 28

2.1. The following clauses 23 to 28 are inserted into the Client Agreement immediately after clause 22.

Prohibited Trading Practices

23.1. The Company provides its services exclusively for genuine, good-faith trading. The Client shall not use any trading strategy, technique, or account structure whose profitability derives primarily from the exploitation of the Company’s pricing, execution, promotions, funding mechanics, or infrastructure rather than from genuine market risk-taking.

23.2. Without limiting the generality of clause 23.1, the following are expressly prohibited:

23.2.1 Exploitation of High-Impact News Events

Trading strategies designed to systematically exploit price gaps, spread widening, execution latency, or liquidity conditions arising immediately before, during, or after the release of scheduled high-impact economic news or unscheduled market-moving announcements, where the strategy’s profitability depends on execution conditions rather than directional market risk. The Company may designate news-event windows during which orders are subject to enhanced review or modified execution conditions under clause 25.

23.2.2 Abusive Hedged and Grid Structures

Position structures — within a single account, across multiple accounts held or controlled by the same person or acting-in-concert persons, or across accounts held at other brokers — that are designed to eliminate genuine market exposure while extracting profit from the Company. This includes, without limitation: (i) simultaneous or near-simultaneous opposite positions in the same or highly correlated instruments; (ii) grid or averaging structures operated without genuine risk controls with the purpose of exploiting stop-out mechanics, negative balance outcomes, or promotional credit; and (iii) coordinated opposite positioning between accounts identified as related by registration data, device, network, or funding source.

23.2.3 Latency and Off-Market Pricing Arbitrage

Strategies exploiting delayed, stale, or erroneous quotations, connectivity or latency advantages, or price discrepancies between the Company’s feed and other pricing sources, including high-frequency round-trip trades whose systematic profitability depends on quote latency rather than market movement.

23.2.4 Manipulation of Margin, Leverage, and Account Funding

Use of deposits, withdrawals, internal transfers, or credit facilities in a manner designed to manipulate margin requirements, exploit leverage tiers, or structure account equity so that losses are borne by the Company while profits accrue to the Client — including rapid deposit-withdrawal cycling, funding patterns inconsistent with genuine trading purposes, and the use of internal transfers to move value generated by prohibited activity beyond the reach of review.

23.2.5 Abuse of Stop-Out and Negative Balance Mechanics

Any strategy or account structure that relies on account stop-out, or on the occurrence of a negative account balance, as a source of value rather than as a consequence of genuine market risk. This includes, without limitation: (i) deliberately allowing one account to be stopped out into a negative balance while a related or coordinated account holds the opposite, profitable position; and (ii) structuring positions or funding across one or more accounts so that adverse outcomes accrue to an account carrying a negative balance while favourable outcomes are retained by the Client on another account.

Nothing in this clause limits the Client’s obligations under clause 14.2, or under clause 14.3 as amended by Part 1 of this amendment, including the Client’s obligation to restore a negative account balance to zero on the Company’s requirement. No provision of this amendment creates any entitlement to negative balance protection, or waives, reduces, or otherwise varies that obligation.

23.2.6 Misuse of Bonuses and Promotional Credit

Use of any bonus, credit, rebate, or promotional benefit outside its intended purpose, including: trading primarily against promotional credit rather than the Client’s own funds in order to extract risk-free profit; withdrawing funds in a manner designed to defeat bonus conditions; coordinating bonus usage across related accounts; and any conduct that converts a non-withdrawable credit into withdrawable funds otherwise than through genuine trading. Volume, rebate, or commission farming through wash trading or minimal-risk trade cycling is likewise prohibited.

23.2.7 Platform and Order-Traffic Abuse

Any use of the trading platform, application programming interfaces, or automated systems (including Expert Advisors) that places an excessive or abnormal load on the Company’s infrastructure or is designed to influence execution or pricing through order traffic rather than genuine trading intent. This includes, without limitation: sustained high-frequency order placement, modification, or cancellation beyond normal trading behaviour; and quote-stuffing or similar techniques.

23.2.8 Copy, Correlated, and Coordinated Group Trading

Replication of a single trading strategy across multiple accounts otherwise than through a money-management or copy-trading program authorised by the Company; and coordinated trading among two or more accounts or persons — whether or not linked by registration data — where the pattern of entries, exits, direction, sizing, or timing indicates a common controller or acting-in-concert arrangement intended to multiply payouts or to implement any practice prohibited by this clause 23. Substantial statistical correlation of trade sequences across accounts may be relied upon by the Company as evidence of coordination.

23.2.9 Related and Coordinated Accounts

Operating, controlling, or coordinating multiple accounts (directly or through nominees) to implement any practice prohibited by this clause 23. Accounts may be treated as related on the basis of, among other things, KYC data, funding sources, device and client-terminal identifiers, IP addresses or network patterns, connection characteristics, and correlated trading behaviour.

23.3 Consequences of Breach

Where the Company determines, acting reasonably and on the basis of its records, that Client activity falls within this clause 23, the Company may, with or without prior notice:

23.3.1. place the account under review and suspend, hold, or reverse any pending internal transfer or withdrawal request, in whole or in part;

23.3.2. cancel or deduct profits, rebates, commissions, or bonuses attributable to the prohibited activity;

23.3.3. void trades executed under prohibited conditions and correct account balances accordingly;

23.3.4. restrict leverage, instruments, order traffic, or execution conditions on the affected account(s);

23.3.5. suspend or close the account(s) and terminate the Client Agreement;

23.3.6. apply the above to any account determined to be related or coordinated under clauses 23.2.8 and 23.2.9.

23.4 Limitations on Deduction

Any deduction under clause 23.3 is limited to profit, rebates, commissions, or credit attributable to the prohibited activity and shall not exceed the net profit so generated, quantified in accordance with clause 23.6 where the account forms part of a coordinated chain. The Client’s deposited principal, net of any deductions properly made under clause 23.3, remains withdrawable.

The limitation in this clause applies to the deduction of profit, rebates, commissions, and credit only. It does not limit, and shall not be construed as limiting, the Company’s right to recover a negative account balance, or any other amount owed to the Company, under clause 14.2, clause 14.3 as amended by Part 1, or clause 22.6.

The Company’s determination is final at the operational level, subject to the review and complaints procedure in clause 24.6.

23.5 Relationship with Clause 22

This clause 23 supplements clause 22 (Trading Abuse, Fair Trading and Compliance) and is to be read together with it. Where the Company makes a determination under clause 22 or this clause 23 in respect of conduct of a kind described in clause 23.2, the limitations in clause 23.4 apply to that determination and to any action taken under clause 22.4 or 22.6 in consequence of it.

23.6 Coordinated Chains

Where two or more accounts are determined to be related or coordinated under clause 23.2.8 or 23.2.9 (a “chain”), the Company may:

23.6.1. quantify the net profit referred to in clause 23.4 on an aggregate basis across all accounts comprising the chain, rather than separately for each account;

23.6.2. set off any credit balance, pending withdrawal, or pending internal transfer on any account in the chain against any negative balance, deduction, or other amount recoverable in respect of any other account in the chain; and

23.6.3. treat each person who controls, operates, or derives benefit from the chain as jointly and severally liable for the aggregate amount recoverable under clause 23.3, clause 22.6, clause 14.2, and clause 14.3 as amended by Part 1.

For the purposes of clause 23.6.3, a person derives benefit from a chain where funds, credit, or value generated by the chain have been transferred to, withdrawn by, or applied for the benefit of that person, whether directly or through a nominee.

Nothing in this clause requires the Company to pursue recovery against every account or person in a chain, and the Company’s election to pursue recovery against one account or person does not waive, release, or otherwise affect its rights against any other.

Account, Transfer & Withdrawal Review

24.1 Continuous Monitoring and Pre-emptive Measures

The Company operates ongoing, automated and manual monitoring of accounts for the practices described in clause 23, independently of whether a transfer or withdrawal has been requested. Where monitoring indicates that an account may be engaged in prohibited activity, the Company may pre-emptively restrict internal transfers and withdrawals on that account, and on any related account, pending review. Accounts trading in a manner consistent with the Client Agreement are unaffected and continue to transfer and withdraw normally.

24.2 Review of Internal Transfers (Trading Account to Wallet)

The Client acknowledges that a transfer of funds from a trading account to the Client’s wallet or to any other account is subject to the same compliance and risk review as a withdrawal. The Company may hold or decline such a transfer where the funds include, or may include, profit attributable to activity prohibited under clause 23. The Client agrees that value generated by prohibited activity may be retained on the trading account and adjusted at source before any onward transfer.

24.3 Withdrawal Pre-Processing Review

All withdrawal requests are subject to a compliance and risk review before processing. The review may include, without limitation: verification of identity and payment-method ownership; review of trading activity for conduct described in clause 23; reconciliation of bonuses and promotional credit; assessment of related-account and coordination indicators; and review of connection and platform-usage records. The Company may request additional information or documentation from the Client for this purpose.

24.4 Processing Times

Standard transfer and withdrawal requests are reviewed within a reasonable period from submission. Where a request is escalated for enhanced review, processing may be extended for the period reasonably required to complete the review, and the Client will be notified that the request is under review.

24.5 Outcomes

Outcome	Effect
Approved	The transfer or withdrawal is processed normally.
Approved with adjustment	The request is processed after deduction of amounts referred to in clause 23.3 (e.g. profits attributable to prohibited activity, unearned bonus amounts), subject to the limitations in clause 23.4. The basis of the adjustment is communicated to the Client in writing.
Declined	The request is declined and the Client is notified in writing of the decision and of the applicable Client Agreement provisions.

24.6 Review and Complaints Procedure

A Client who wishes to contest a decision made under clause 23 or this clause 24 may do so by responding in writing to the notification received. The Company will acknowledge the enquiry, register it, and provide a substantive written response within a reasonable period, ordinarily within five (5) business days and, for matters involving multiple accounts or extended trading periods, within ten (10) business days. A Client who does not accept the outcome may request a final internal review by the Company’s Risk & Compliance function. On request, the Company will provide the Client with the Client’s own account records relied upon and the specific provisions of the Client Agreement applied. This procedure does not limit any right the Client may have under applicable law or under the Company’s complaints procedure.

Risk-Management Measures the Company May Apply

25.1. To protect the integrity of its platform and to manage risk arising from the practices described in clause 23, the Company may, at its reasonable discretion and on a non-discriminatory basis, apply operational measures to accounts or instruments, including, without limitation:

25.1.1. reducing available leverage ahead of weekends, market closures, or scheduled events carrying elevated gap risk;

25.1.2. applying modified margin requirements or execution conditions during designated high-impact news windows;

25.1.3. limiting order-submission rates or automated order traffic that places abnormal load on the platform;

25.1.4. restricting or adjusting trading conditions on accounts under review under clause 24.

25.2. Such measures are risk-management controls applicable to trading conditions and do not, by themselves, constitute a determination of breach under clause 23.

Account Monitoring and Data Use

26.1. In addition to website monitoring, the Client acknowledges and agrees that the Company records and analyses, for compliance, security, fraud-prevention, and risk-management purposes: trading server logs, including order and execution timestamps; login records including IP address, device and client-terminal identifiers; network telemetry including connection latency; funding and balance operations; and promotional credit usage. This data may be used to identify prohibited practices under clause 23, to establish relationships and coordination between accounts, and to support decisions under clause 24.

This clause is to be read together with clause 22.7, which sets out the categories of evidence the Company may rely upon in making a determination. Where permitted by applicable law and consistent with the Company’s Privacy Policy, the Company may share limited information with other regulated entities and fraud-prevention bodies for the purpose of preventing and detecting the practices described in clause 23. All personal data is processed in accordance with the Company’s Privacy Policy.

Order Execution

27.1 Discretion to Determine Execution Model

The Client acknowledges and agrees that the Company may execute, route, or hedge the Client’s orders on either a principal basis (the Company acting as counterparty) or an agency/pass-through basis (orders transmitted to and hedged with one or more upstream liquidity providers), or a combination of the two, at the Company’s sole and reasonable discretion. The Company may change the execution model applicable to a Client’s account, or to specific instruments within it, at any time and without requiring the Client’s prior consent, by giving notice where required by applicable law.

27.2 Basis for Determination

In determining the execution model applicable to an account, the Company may have regard to the account’s risk profile as assessed under the Company’s internal risk-management procedures and to the Company’s overall risk-management and hedging requirements. A change of execution model under this clause is a risk-management measure and does not, by itself, constitute or imply a determination of breach under clause 23.

27.3 No Disadvantage to Order Execution

A change in execution model under this clause shall not itself result in the Client receiving materially worse pricing than that generally available under the Company’s published trading conditions for the relevant account type and instrument. Any difference in spread, commission, or execution characteristics between execution models is as disclosed in the Company’s trading conditions schedule from time to time.

Promotional Credit Eligibility and Administration

28.1 Discretionary Nature of Promotional Credit

Bonuses, credits, cashback, and rebate-program benefits (together, “Promotional Credit”) are provided entirely at the Company’s discretion, subject to the terms of the relevant campaign. Promotional Credit does not form part of the Client’s own deposited funds and is not withdrawable except to the extent, and in the manner, expressly provided by the applicable campaign terms.

28.2 Restriction of Future Eligibility Following a Clause 23 Determination

Where the Company determines under clause 23.3 that an account has engaged in activity prohibited by clause 23, the Company may restrict that account’s eligibility to receive Promotional Credit, participate in campaigns, or take part in cashback or rebate programs, indefinitely or for a specified period, with notice to the Client. This restriction is prospective only and does not affect Promotional Credit already converted into withdrawable balance in accordance with the applicable campaign terms before the restriction takes effect.

28.3 Removal of Unused Promotional Credit During Review

Where an account is placed under monitoring or review under clause 24, the Company may cancel any Promotional Credit on that account that is active, not yet expired, and not yet converted into withdrawn balance, with notice to the Client. This clause applies only to the outstanding Promotional Credit itself; it does not affect the Client’s own deposited principal or any profit already realised and withdrawn from the account.

28.4 Reversal

Where a review under clause 24 concludes without a determination under clause 23, the Company will, on request, reconsider any restriction applied under clause 28.2 and any cancellation applied under clause 28.3, and may reinstate the Promotional Credit or eligibility, at its discretion and having regard to the remaining terms of the original campaign.

Abnormal market conditions mean Fast market.

Account history means records of completed transactions and non-trading operations on a Client’s trading account.

Account type means a type of a trading account. The types of accounts offered by the Company are available on the official website of the Company The Client cannot change the type of account once it has been created.

Affiliated accounts are the trading accounts opened by affiliated persons noticed by the use (but not limited to) of the same identification details, payment or network details (accounts managed from one IP address, or/and with the same cid are deemed as a single trading account).

Affiliated persons are the individuals, whose relationships can impact on the terms or financial results of the Company’s activity. Affiliated persons can be deemed as such if their passport details, address, phone number, email address, IP address, cid, payment details etc are the same.

Ask means the higher price in the quotation; the price a Client can buy.

Balance means the total financial result of all completed transactions and depositing/withdrawal operations (except for credit operations) on the trading account.

Bar/Candle means a feature of a price chart that shows the opening and closing prices, as well as the lowest and highest prices for a definite period of time (for example, 1 minute, 5 minutes, a day, a week).

Base currency means the first currency in a currency pair or the currency in which the asset, underlying the Contract for Difference (CFD), is nominated.

Bid means the lower price in the quotation; the price a Client can sell at.

CFD (Contract for Difference) means a contract, which is a contract for difference by reference to fluctuation in the price of the underlying asset (shares, currencies, futures, goods, indices etc.)

Clearing means non-cash settlement between the Company and its contractors, banks and liquidity providers implemented through mutual settlement based on the terms of cooperation. When clearing is conducted, no quotations are present on the Trading server, (non)-trading operations are prohibited.

Client agreement means the agreement between the Company and a Client, which together with proper policies and documents allocated at the Company’s website, govern the relations by and between the Company and a Client.

Client means a legal entity or individual who works with the Company through agreements that involve margin transactions.

Client’s e-mail – e-mail address specified in a Client’s Personal account (myfreshforex.com). Requests sent from other email addresses will not be considered by the Company.

Client terminal log-file means the file created by a Client terminal which records all Client requests and instructions to the Dealer with accuracy to the second.

Client terminal means the software product which is used by a Client to get information on trading in financial markets (in the volume determined by Company) in a real-time mode, conduct technical analysis of markets, implement transactions, send/edit/cancel orders as well as to receive information messages from Company. Price charts in the terminal are built on the basis of Bid prices. The program can be downloaded on the Company’s website.

Closed position means a result of covering an opened position by the opposite position. As a result of closing of a position the Company has an obligation to fix floating profit/loss on balance of a Client.

Company is any legal entity in Otet Companies Group, which provides services in accordance with the Client Agreement.

Company’s website is the website of the Company at https://www.otetmarkets.com.

Contract specifications mean the primary trading conditions (spread, lot size, the minimum volume of a transaction, swaps, initial margin, etc.) for every financial instrument. For more information about trading conditions go to a Client terminal.

Contractors and partners of the Company are liquidity providers, banks, brokers and other organizations the Company cooperates with.

Conversion arbitrage operations mean transactions between the Company and a Client concerning buying or selling currency contracts or CFD.

Currency of account means funds or underlying asset in which the sum amount of all trading and non-trading operations are nominated and calculated including floating profit and loss, commission payments, marginal requirements. Currency of account can be USA Dollars (USD), Euro (EUR) and other currencies specified in the website of the Company. Currency of the account is selected when the trading account is opened and cannot be changed in the future. Currency means the object of transaction based on the change in the value of one currency against the other.

Demo account – a training trading account with virtual funds provided by the Company, designed for trading without using real money. This account will not be taken into account in the Personal account, withdrawal and transfer to other accounts cannot be made.

Dispute means 1) a conflict arising when a Client believes that the Company, as a result of any action or omission has breached one or more of the contractual arrangements; 2) the Company believes that a Client, as a result of any action or omission, has breached one or more of the contractual arrangements; 3) when a Client makes a trade on an error quote (spike), or before the first quote comes to the Trading Platform at market opening, or on a quote received by a Client due to manifest error on the part of the Company or software failure on the Trading Platform.

Dynamic password means a code intended for withdrawal of funds from a Client’s trading account. The dynamic password is sent as SMS to a Client’s mobile phone number specified by the account registration. All withdrawal requests from a trading account that are not confirmed by a dynamic password shall be automatically rejected.

Equity means a provided part of a Client’s account with regard to open positions; equity is calculated as follows: Balance + Floating Profit/Loss + Swap. These are assets on the Client’s account reduced by the current loss, commissions with regard to the open positions and enlarged by the current profit with regard to the open positions.

Expert advisor, Mechanical Trading System means an algorithm for managing the trading account in the form of program written in a specialized Meta Quotes language which automatically directs requests and orders to the server, using a Client’s terminal. Client bears the full responsibility for actions done by the Expert Advisor.

Explicit error means either the execution (processing) of an order on the quote which does not correspond with an actual average price level at the time of the implementation of such an operation, or the execution in contradiction to the Company’s regulation documents and/or common business practice.

Fast market means a market characterized by rapid price fluctuations over a short period of time often causing price gaps. A fast market may occur immediately before or after important events such as:

a) Release of influential macroeconomic indicators for the global economy;

b) Decisions by central banks on interest rates;

c) Press conferences and statements by central banks officials, heads of state, financial ministers or other significant announcements

d) Government intervention in the currency market

e) Terrorist attacks of great impact

f) Natural disasters leading to the declaration of a state of emergency (or comparable measures) in the affected regions

g) War or other significant military actions

h) Political force majeure: dismissal or appointment (including election results) of top government officials

i) Other events which cause significant price movements.

Feed means quotes on each financial instrument entering the Trading Platform.

Financial instruments mean currency pairs, shares, goods, other assets, indices, other instruments, and CFD contracts available for trading.

Financial result is a profit or loss, formed based on Client’s trading operations together with all swaps and commissions. When opening a transaction, it will be considered in the Equity, when closing a transaction, it will be considered in Balance.

Fixed spread implies a permanent difference between Bid and Ask of a financial instrument. The majority of assets have fixed spread.

Floating profit/loss means floating (unrealized) profit (loss) with regard to open positions at the current quotes. Floating spread implies dynamic (changes over the time) difference between Bid and Ask of financial asset. The majority of assets have floating spread.

Force majeure means unforeseen and unpreventable events such as: a) nature disaster; b) war; c) terrorist attack; d) Acts of government; e) hackers’ attacks and other illegal actions against the Company.

Free margin means equity not employed in the opening of a position and can be used for new positions. Free margin is calculated as follows: Free Margin = Equity – Margin.

Calculation of free margin for new positions is based on the formula:

1. Volume of client position and new margin are defined: for locked positions it is based on the margin required to cover trades, for other positions it is based on the initial margin which is defined by weighted average price (regarding volume) of all positions with the exception of covered;

2. Entire current Floating profit/loss on all open positions is defined based on current prices;

3. Free Margin formula: Free Margin = Balance – New Margin + Floating Profit/Floating Loss.

Freeze level means the range of points in each side of the price declared by a client at which the order must be executed (opening prices of the pending order, stop-loss or take profit prices of the open position). If the current market price is in the established range, then order may be banned, changed deleted or closed. During the main time trading is usually performed without order freeze levels, but when sharp price changes of financial instruments happen (after the issuance of fundamental data, interventions in illiquid market etc.), the company has the right to set freeze levels up to 3 standard spreads.

Gap (price range) means a situation when the current quote differs from the previous one in more than a spread size. It may occur both within a trading session on publication of relevant macroeconomic data, economic and political news or in case of force majeure events and at the market opening after weekends and holidays.

Hedged margin means the margin required by the Company to maintain locked positions. The details for each financial instrument are specified in the contract specifications on the Company’s website and in its Trading Server.

The margin is taken for each covered lot based on the value specified in “Hedging” field in properties of the financial instruments. If the initial margin is set for the contract, hedged margin has the money expression.

Inactive account is an account, on which no operations are initiated by a Client for more than 30 (thirty) calendar days (deposits, withdrawals, trading operations).

Internal exchange rates of the Company — quotes (prices), at which the Company converts funds or assets of Clients during the execution of non-trading operations. Internal exchange rates are set at the discretion of the Company and may be changed at any time without notifying Clients, depending on the market situation, market volatility and other external and internal factors. Up-to-date rates are published in the Client area and include:

1) Internal exchange rate on depositing (crediting) is used for conversion funds or assets sent from a Client’s payment details, when crediting funds to a Client’s account in the Company.

2) Internal exchange rate on withdrawal is used for conversion funds or assets sent from a Client’s account in the Company to a Client’s payment details.

3) Internal exchange rate on transfers is used for conversion funds or assets when transferring funds between accounts in the Company denominated in different currencies.

Interdependent accounts (Interdependent Personal Areas) – trading accounts (Personal Areas) opened by the interdependent individuals, including but not limited to the intersection of identity, payment and network data of the Partner and a Client (accounts trading from the same IP address and/or with the same CID are regarded as one active account), opening of oppositely directed trades on the same or correlated financial instruments.

Interdependent individuals – individuals whose inner relationships can impact on the financial condition or financial results of the Partner and the Company.

Labor hours of the Company means a time interval within a working week, when the trading terminal of the Company provides transacting with standard currency contracts as well as with standard CFD contracts, except weekends and holidays, temporary changes of the internal service of the Company and a period of time when services cannot be provided to Clients for some technical reasons. In such cases, the Company is obliged to take measures to inform a Client on changes concerning the routine of work and give a chance to a Client to eliminate the currency risks appearing as a result of the foresaid.

Leverage means ratio between the transaction volume (in terms of currency) and the margin. The leverage 1:100 means that the Client needs a sum in 100 times less than it is needed to open a position.

Liquidity provider – partner of the company: broker, bank or ECN providing streaming quotes and used by the Company to hedge Clients’ trades.

Limit & Stop Levels are the minimal distance in points from the Open level to current prices, works for all types of orders: Stop Loss, Take Profit, Buy Limit, Sell Limit, Buy Stop, Sell Stop, Buy Stop Limit, and Sell Stop Limit.

Locked (covered) positions mean long and short positions of the same size opened on the same trading account with regard to the same financial instrument.

Long position (Buy) means market liability, the number of bought contracts on financial instrument expecting rise in quotation. With regard to currency pairs: buying the base currency for the quoted one with regard to CFD: buying base asset CFD for quoted currency.

Lot, Lot Size means a conditional indication of the number of base currency, shares or basis asset as defined for financial instrument.

Lot size (contract size) means a measure unit of the trade volume (for example, 1.00 lot = 100,000 base currencies), it’s specified on the Company’s Trading server and in the contracts specification on the Company’s website.

Margin means the money security required to open and maintain trading positions.

In general case, margin for a Client’s account is the sum of margin requirements on all open positions with the exception of covered (hedged or locked) positions. Covered positions are the positions opened for one contract in opposite directions. Margin is different for various financial instruments and its level is specified in the Trading Server of the Company. A Client does not show it in properties of contracts. Margin for each contract (financial instrument) is specified on the Company’s website.

Margin call means a warning that informs a trader on insufficient funds required for maintaining open positions which, in some cases, can lead to closing positions without notification to a Client. Occurs when Margin level is equal or less than Margin call.

Margin level is the key level of account characterizing if the funds on trading account are enough to maintain open traders. It is calculated based on the formula: Margin level = Equity/Margin * 100%. If Margin level falls below allowed level set by the Trading Procedures, Stop Out Occurs.

Market order is the trading instruction of a Client to the Company to Open/Close a position of financial instrument based on current price.

Market price available means a quote at which a liquidity provider executes a Client’s order. The Company cannot guarantee the execution of the order at a price better than the price offered by a liquidity provider. The accuracy of quotations is determined by the Company, at its sole discretion.

Margin trading means leverage trading when a Client may make transactions having far less funds on its/her/his trading account.

Market opening means the time when the market opens after weekends, holidays or trading session time gaps.

Non-trading operation means deposit/withdrawal of funds or providing/return of a bonus or a credit.

Normal market conditions mean: a) no considerable breaks in the flow of quotes; b) low volatility; c) no large price gaps.

Open position means market liability, number of bought and sold contracts on financial instruments not covered by the opposite buy (sell) of the contract. In this case the Client shall be obliged to maintain equity not lower than pointed by the Company.

Order level means the price specified in the order.

Order means a Client’s instruction to the Company to buy or sell a financial instrument. There are two types of orders: market order and pending order.

Pending order means a request from a Client to the Dealer to carry out an order (open or close position, place an order) once the price reaches the level of the pending order. A Client may place pending orders of the following types: Stop Loss, Take Profit, Buy Stop, Sell Stop, Buy Limit, Sell Limit, Buy Stop Limit, and Sell Stop Limit.

Personal area means a Client’s personal cabinet on the Company’s web page where the Client’s contact details are specified, as well as deposit/withdrawal requests and feedback to the Company are carried out.

Photo ID means a high quality photo of a Client holding his/her identification document. The face of a Client and his/her identification document should be clear and well visible. Graphical editor usage for adjustment of the photo is prohibited.

Point (Pip) means a minimal change of the financial instrument rate.

Position means market liability, number of bought and sold contracts on financial instrument.

Promotion account (account that is a part of promo) – a special trading account where trading is done with money given by the Company. The Company’s money and money received as a result of trading operations on the promotion account shall be used in accordance with the terms of promo activated.

Quote currency means the second currency in the currency pair which can be bought or sold by a Client for the base currency.

Quote means the price of one currency quoted in terms of another, or price of various financial instruments (Bid/Ask).

Quotes base means information about the stream of quotes.

Quoting means the process of providing a Client with quotes.

Rate means 1) for the currency pair: the value of the base currency in the terms of the quote currency; 2) for CFD: the value of the unit of the underlying asset in terms of money, 3) for other financial instruments: the assets value in terms of money.

Request means Client’s order to the Company given to obtain a quote. Client is not obliged to implement a transaction on making such a request.

Server log means a file where the server protocols all requests and orders received from a Client as well as the result of their processing with a pinpoint accuracy.

Short position (Sell) means market liability, number of sold contracts on financial instrument held with the expectation of the asset falling in value. In currency trading it means buying the quote currency and selling the base currency. As applied to the Contracts for Difference: selling the base asset CFD for quoted currency.

Spike means an error quote with the following characteristics: a significant price gap; in a short period of time the price rebounds with a price gap; before it appears, there is no rapid price movements. The Company has a right to remove a non-market quote from the quote base of the Trading server.

Spread means the difference between the buying rate and the selling rate of a currency pair or a CFD contract at the present moment.

Stop out means an automatic Trading server’s command to close one or more open positions without any prior notification to a Client. Occurs due to insufficient funds required for maintaining open positions in trading account when Margin level is equal or less than Stop out level, which is specified in the section “Trading conditions” on the Company’s website.

Swap (Rollover) means amounts charged off or credited to a Client’s account for the position prolongation (transfer) to the next day. Calculation and fixing of swaps occur at the last moment trading days on server time (from 23:59 till). Swap sizes are determined in the contract specifications on the web site of the Company.

Telephone password (Code word) means an additional password of a Client, which is used without fail when executing transactions by telephone.

Ticket means the unique identity number assigned to each trading and non-trading operation.

Trade means buying or selling a financial instrument. Buy operation is carried out at Ask price, and Sell operation is carried out at Bid price. A trade may be executed as a result of market order or pending order.

Trading account means the special personal account opened by a Client with the Company where the obligations between the Company and a Client are conducted which arise from the trading and non-trading operations made within the scope of the Agreement.

Trading commission is the fee charged by the Company from a Client for performing a Trading operation.

Trading instruction means Client’s order to the Company to open or close a position or to place, modify, delete an order.

Trading operation means buying or selling of any financial instrument with the intention of the opposite transaction (selling or buying, respectively) of the same instrument and amount.

Trading platform time zone means Eastern European Time, EET is equal to GMT+2 in winter and GMT+3 in summer. Graphics in terminal as well as recording of any event in the log file of a Trading server are reflected according to EET.

Trading server of the Company means software of Meta Trader Server by means of which Client’s instructions and requests are processed, the information on trading in financial markets (in the volume determined by the Company) is provided in real time mode, the mutual obligations between the Company and the Client as well as adherence to contract specifications and restrictions are registered.

Transaction means a conversion of funds from the base currency (asset) to the quote currency and vice versa as a result of trading operations.

Transaction size means lot size multiplied by the number of lots.

Volume of trading operation – product of a number of lots by volume of lot.

1. The Client hereby acknowledges, represents and warrants that he/she/it has carefully designated a part of his/her/its assets (Owned Capital) as the Risk Capital. The Client further acknowledges that the Risk Capital is an amount that he/she/it prepares to dispose at risk and the loss of this amount will not significantly impact his/her/it financial well-being.

2. The Client hereby acknowledges that trading in foreign exchange, CFDs, shares, goods, other instruments, carries a significant risk of loss. Therefore, the Client must thoroughly assess his/her/its financial capacity and suitability for engaging in such transactions.

3. Upon opening a trading account, the Client selects the deposit currency from the options provided by the Company. All trading and non-trading transactions on the trading account, including floating profits and losses, commissions, fees, charges, other payments, and marginal requirements, are conducted and settled in the chosen currency. The Client accepts and assumes full responsibility for all the risks or consequences associated with of change of deposit currency.

4. When performing non-trading transactions, the Client independently chooses the method and currency of transfer from the options provided by the Company. The Client acknowledges and accepts all the risks arising from fluctuations in the Company’s internal exchange rates, and assumes full responsibility for any resulting consequences.

5. The Client acknowledges that he/she/it may lose all the initial Risk Capital and any additional Risk Capital deposited to support and maintain his/her/its market positions. Furthermore, market conditions may result in losses exceeding the remaining balance in the Client’s trading account.

6. Placing limit orders such as Stop-Loss does not guarantee that losses will be limited to the specified amounts, as certain market conditions or some external factors may disrupt the execution of such orders.

7. The high level of fluctuations typically observed in the trading, combined with relatively not high margin requirements, can work both for you as well as against you. These fluctuations may result in both significant losses and substantial profit. The Client assumes full responsibility for all risks, financial resources used and the chosen trading strategy.

8. When performing trading operations through the client terminal, the Client shall assume the risk of financial loss, which can be caused by the following:

a) Failure or malfunction of the Client hardware, software and Internet connection;

b) Improper operation of Client equipment;

c) Incorrect settings configured within the client terminal;

d) Delayed in the Client’s terminal updating to the latest version;

e) The Client’s ignorance of the applicable rules outlined in the MetaTrader User Guide.

9. The Client acknowledges that only one request, instruction or order may be processes at a time. Any additional requests, instruction or orders submitted by the Client while the previous one is still in the queue may be declined, delayed.

10. The Client acknowledges that the only reliable source of quote information is the server designated for live accounts. The quote database displayed in the Client’s terminal shall not be considered reliable, as during the periods of high market volatility or poor connection between the Client’s terminal and the server, certain quotes simply may fail to reach the Client’s terminal.

11. The Client shall acknowledge that once a request, instruction or order to place/modify/delete, or to open/close a position, is sent to the server, it cannot be canceled by closing the corresponding window in the Client’s terminal.

12. The Client acknowledges and agrees that in the event of Stop Out (situation, when Margin Level reaches or falls below the Stop Out value determined in Trading Conditions section on the website of the Company), the liquidation of open positions will occur automatically. This process works independently on any actions by the Company, and any intervention by the Company is unacceptable.

13. The Client acknowledges and agrees that the trade server checks the availability of the sufficient Free Margin level on the trading account, when the Client tries to open a new position. However, it does not consider upcoming expenses, such as spread and commission, fees, other charges, associated with maintaining the current position. Due to high leverage, the Client may open a position of such volume that actual expenses for spread and commission, fees, other charges, could result in insufficient funds on the trading account, triggering the forced closing of positions.

This occurs when Margin Level reaches or falls below the Stop-Out value as specified in the Trading Conditions section on the website of the Company.

In this case the Client assumes full responsibility for losses incurred as a result of this situation, as the Client determines volume of his/her/its new positions.

14. The Client acknowledges that the Company is not held liable for any losses caused, whether directly or indirectly, by government restrictions, currency or market rules, interruptions, disruptions in markets trading, military operations or any other circumstances, usually classified as “force majeure” and which are beyond the Company’s reasonable control.

15. Transacting by means of electronic trading system may differ from both, transacting in the interbank market, as well as from transacting based on other trading systems. When the Client transacts using an electronic trading system he/she/it assumes the risk associated with the electronic trading system, including any software issues.

16. The Client undertakes to maintain the password in secret and prevent unauthorized access to the Personal Area and trading accounts. The Client is bound by trade obligations in respect of the Company for trades done using the Client’s password, even if it is used by a third party.

17. If any quote fails, the Company is entitled, but not obliged to, to make necessary changes and resolve any disputes immediately.

18. The Company is not responsible for payment processing delays, failures, or disconnection caused by third parties. The Company will not reimburse for any direct or indirect losses and moral damage resulting from such delays, failures and/or disconnections.

19. The Client acknowledges and agrees that the Company shall not be liable for his inability to authorize in the Client Area or trading account.

20. This brief risks notification does not address all the risks associated with the trading on financial markets.

21. Day trading is a high-risk activity unsuitable for individuals with limited resources, experience, or low risk tolerance, as it often leads to the loss of all Risk Capital. It should never be funded with money essential for retirement, education, emergencies, or living expenses. Those considering day trading must understand its speculative nature and ensure it does not jeopardize their financial well-being.

This Privacy Policy governs privacy of the clients, visitors, partners, representatives, beneficial owners of clients – legal entities, partners-legal entities (“you”, “your”, “user”) of https://otetmarkets.com (“Website”), served and operated by us,

1) Otet Group Ltd., a company duly incorporated in Saint Lucia, registration No. 2023-00595, being a brokerage company, and

2) Otet Group LTD, a company duly incorporated in the Comoros Union (Mwali), registration No. HY00523012, holding a valid Brokerage License

(“we”, “us”, “our”, the reference to the “Company” means the reference to each of the above companies) and describes what Personal Data is collected and how it is used, processed, stored and managed by us, under the applicable legislation, while you visit or use our Website, our services (the “Services”) or enter into partnership agreement with us (“Partnership Agreement”).

One of our main priorities is to protect the privacy and safeguard of the personal and financial data of our current and potential clients, partners and the Website visitors. It is explained in this Policy how the we collects, processes and protects the Personal Data.

Note: the present Policy extends only on the Website and does not extend on websites of other companies, persons or the organizations references on which contains the Website.

This Privacy Policy also serves as a privacy notice, informing you about why and how we collect and manage your Personal Data.

If you use our Services, execute Partnership Agreement, you acknowledge that you have read and understood all of the terms and guidelines. By using our Services, executing Partnership Agreement, you expressly agree to this Privacy Policy and expressly consent to and agree to the processing of your Personal Data as set forth herein. Consent provided by you under this Privacy Policy is treated taken as given in a written form.

This Privacy Policy is governed, construed, interpreted, and enforced in accordance with the laws of Comoros, Saint Lucia, and the European Union. If any term of this Privacy Policy is found to be inapplicable or unenforceable under the law, it will have no effect on the application or enforceability of the remaining elements of this Privacy Policy. If you do not agree with this Privacy Policy, you should immediately stop using our Website, Services, terminate Partnership Agreement.

We reserve the right to change, vary, and revise this Privacy Policy whenever lawfully required or in light of marketing, commercial, technological, or other upgrades, or as we deem necessary. Unless clearly specified differently, such revised or updated versions will take effect as of the publishing date. By using our Website, Services, executing Partnership Agreement, you agree to and accept the terms of this Privacy Policy, including its modifications. If you do not agree with any revision, alteration, or update, you must discontinue using our Website, Services, terminate Partnership Agreement.

1. GENERAL PROVISIONS

The Company is responsible for Personal Data in its possession or custody, including information that has been transferred to a third party for processing.

The Company hereby confirms that it in compliance with the the GDPR, Data Protection Act of Saint Lucia (related to the Company registered in Saint Lucia), proper data protection regulation of the Comoros (related to the Company registered in Mwali) (the “Applicable Legislation”).

We only use Personal Data for the purposes outlined in our Privacy Policy. We only transfer your Personal Data to other parties if it is necessary, as described below.

The collection of Personal Data is limited to that which is necessary for the purposes identified by us. Both the amount and the type of information collected is limited to that which is necessary to fulfil the purposes identified.

The Company uses contractual means to provide a comparable level of protection while the information is being processed by a third party.

The Website or programming interface necessary to access the Services may contain links to third-party websites, plug-ins, and apps. Clicking on those links or activating those connections may allow third parties to collect and share data about you. We have no control over these third-party sites and are not responsible for their privacy statements and policies.

Collecting and processing of the Personal Data by us is mandatory, if you use the Website, our Services, enter into Partnership Agreement relations with us. If you reject providing necessary Personal Data to us, we are entitled to reject in entering into contractual relations.

2. PERSONAL DATA THAT COULD BE COLLECTED BY US

Depending on whether and how a client, partner uses our Website, Services, how a partner interacts with us under Partnership Agreement, we will collect, use, store, and transfer various types of your Personal Data, which are divided into the following categories.

Category of Personal Data	Types of data
Identity Data	Your e-mail address, first name, maiden name, last name, username or other identifier, date of birth, gender, residential address, postal address, citizenship, contact phone number, trading account, demo account details, partner’s account details, your Personal Area details, source of funds, and wealth. Identity documents (national identity cards, passport, driving license or other forms of identification documents), proof of address documentation, occupation, employment industry, financial standing. Confirmation that you are a director, board member, employee, representative, or an owner or an ultimate beneficial owner etc. of a company being our client, partner, information on the ownership and control structure of a client – legal entity, a partner – legal entity. Please note that we may also ask you to prove ownership or control of a particular your external account to which and from which the transfers are made to and from the trading account, partner’s account opened with us. We are required to ask for this information to comply with Anti-Money Laundering (“AML”), Counter-Terrorism Financing (“CTF”) requirements, and to ensure we safeguard against and report any suspicious activity.
Biometrics	Photo, video, audio of Personal Data subject, other biometric identifiers and/or biometric information of Personal Data subject.
Partnership Information	Structure of partners (Master Partner and Sub-Partners, their connection, tiers), each partner’s ID, referral link, each partner’s group clients, other details, calculation of commissions, other payments due to each partner, calculations history.
Social identity data and Preference Data	Data on referrals to you, close connections, preferences, interests, favorites, risk assessment, compliance evaluation, work address, and groups. Your marketing and communication preferences, survey replies, and connections with others whose Personal Data we may collect or store.
Verification Data	Personal Data which we collect for the purpose of conducting client, partner due diligence under applicable AML/CTF laws, photo, direct video transmission recording.
Background Data	We collect as well Personal Data available in open source.
Transactions, operations data	Personal Data regarding your trading operations, non-trading operations, transactions activity logs, billing, settlement details obtained by us when you use our Services, perform your role under the Partnership Agreement; trading and non-trading orders, instructions, transfers detail, history; other details of any operations, transactions you enter into using the Website, Services, or initiate, perform under Partnership Agreement; partner’s commission accrual and payment (including to master partner, sub-partner).
Technical Data	Domain and host from which you access the Internet, operator and carrier data, your computers or other usable devices IP address, device type, category and model, web browser type and the operating system software, unique IDs of your devices, time zone setting, location data, language data, operating system and platform, diagnostics data such as crash logs and any other data we collect for the purposes of measuring technical diagnostics, and other data.
Profile Data	Your username and password, login data, your identification number as our client, partner, requests by you for Services, requests under Partnership Agreement, communication between us and you, a client or partner.
Marketing and Communication data	Your preferences in receiving marketing from us or third parties, communication between us and you, your survey responses, voice record of communication between you and us.

This data is not exhaustive and is intended to provide you with an idea of how to use fundamentally obtained data. We shall keep a record of the data collected and the purposes for which it is processed.

It may be impracticable to deal with you on an anonymous basis or using a pseudonym.

Please be noted, that if you directly disclose your Personal Data, or sensitive Personal Data (such as, among others, racial or ethnic origin, political opinions, religious beliefs or other beliefs of a similar nature, physical or mental health, membership in any organizations etc.), through public features, this information may be collected and used by other persons.

Furthermore, we consider certain categories of Personal Data to be sensitive, and such sensitive data requires additional safeguards. We will only collect, use, store, and transfer your sensitive data if we can meet both, the legal basis requirement and at least one of the required extra conditions.

The additional conditions are as follows:

circumstances specified by regulatory rules: Personal Data are processed in such circumstances prescribed by regulations;
consent: you have given consent to the processing of your sensitive data;
information made public by you: the sensitive data has become public as a result of your actions;
legal proceedings: the processing is necessary for the purpose of, or in connection with, any legal proceedings, for obtaining legal advice, or is otherwise necessary for establishing, exercising, or defending legal rights;
public functions: the processing is necessary for the exercise of any functions conferred on any person by or under an enactment.

3. PERSONAL DATA PROCESSING PURPOSES

For the purposes of the applicable law, we as Data Controller of your Personal Data must securely retain any data submitted by you to us and/or received by us otherwise.

We may use your Personal Data, for the following purposes (which are considered to be informed to you before or when you (or client – legal entity where you are a representative, or beneficial owner) start using Services, Website, execute Partnership Agreement):

Purpose	Details
Contractual Purpose	to register you at our Website, to enter into, perform agreement, Partnership Agreement, and deliver Services properly (which may include disclosure to relevant third parties as defined by us); to process and deliver Services and any Website features, additional benefits from partnership, to you, including to execute, manage and process any trading and non-trading instructions or orders you make; to manage, process, collect and transfer payments, trades, transfers, fees and charges, and to collect and recover payments owed to us;
Analytical Purpose	to collect general and particular statistics of the Website use, activities of clients, for sending communications, notices, updates, surveys; for client service support and ancillary purposes; to collect statistics regarding use of our Website concerning visits and activities of clients, potential clients on our Website, including analytics services such as Google Analytics, etc. (this analysis helps us run our Website more efficiently and improve and personalize client’s online experience), to keep our records updated and to study how clients use our Services;
Marketing and Advertising	to send you welcome email following registration procedures; to send you occasionally our Services updates, partnership terms and conditions; to contact you for surveys purposes (you do not have to respond to such surveys); for other marketing purposes; to advertise our Services, partnership to you and understand the effectiveness of the advertising we serve to you. We could use your Personal Data and decide which Services and offers may be relevant for you. You will receive marketing communications from us if you have requested information from us and consented to receive marketing communications, or if you have purchased from us and you have not opted out of receiving such communications.
Compliance Purpose	to maintain accuracy of our records; to verify your Personal Data for the purpose of managing our client relationships and observing the Know Your Client (“KYC”) rules; to comply with legal and regulatory obligations with respect to AML/CTF, prevention of criminal activity and lawfully protect our legal interests, make relevant risk assessments and management; to use the services of financial institutions, crime and fraud prevention companies, risk measuring companies; background checks, detect, investigate, report and prevent financial crime in broad sense, obey laws and regulations which apply to us and resolving them;
Communication Purpose	to contact a client for administrative purposes such as client support service, address technical or legal issues related to the Services provided, partnership, or share updates and notifications about the Services, partnership. Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. If you need details about specific grounds for Personal Data processing by us, please contact us.

We will only use your Personal Data for the purposes for which it was collected, unless we reasonably believe that we need to use it for another reason, which is compatible with the original purpose. If you need an explanation of how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your Personal Data for an unconnected reason, we will tell you and explain the legal basis for doing so.

We may also need to process your Personal Data in connection with or during the negotiation of any merger, financing, acquisition, business transfer, assignment, bankruptcy, dissolution, transaction, or procedure involving all or a portion of our shares, company, or assets. This will be based on our legitimate interests in carrying out the transaction or meeting our legal responsibilities.

4. SOURCE OF OBTAINING YOUR PERSONAL DATA

From the client when the client provides Personal Data for identification, verification and KYC purposes;
From you when you visit our Website, and/or use Services, partnership relations with us;
From you when you enter into an agreement with us;
From you when you submit any requests, complaints, e-mails to us;
From financial institutions, other entities;
From registers;
From our partners, such as identification/verification vendors;
From other sources.

We use different methods to collect information from and about you, including through:

Direct collection

A client may provide us with Personal Data by directly communicating with us, such as by filling out forms, uploading a visual image of yourself to the service, sending an email, or otherwise. This includes Personal Data a client supplies when applies for Services, visits our Website, Services, enter into Partnership Agreement with us, provides feedback or contacts us, responds to advertisements sent to a client, or participates in a poll, including through social media channels. We also collect Personal Data when we provide assistance or support to clients or potential clients regarding our Services, support to partners.

Automated technologies

When you connect with us through our Website, we will automatically collect your Personal Data. We collect this Personal Data using cookies, server logs, and other methods. Though such information is not submitted by a client, it relates to you and is considered Personal Data under the Applicable Legislation. It has two subtypes: 1) Static (once created, this information usually remains constant. For example, an internal user id. 2) Dynamic (this subtype fluctuates depending on the activities you conduct).

Publicly available sources or indirectly collected Personal Data

We also obtain information about you from third parties or publicly available sources, or when a client does not provide it directly (e.g., an IP address).

5. LEGAL BASIS FOR PERSONAL DATA PROCESSING

Processing is necessary for the entry into or performance of an agreement between the client and us, partner and us, for performance of the agreement to which our client or partner is a party. We are is processing Personal Data for contractual and communication purposes, for entering into or for performing an agreement entered into between us and the client, us and a partner;
Processing is necessary for compliance with a legal obligation to which we are subject, for compliance with a legal obligation to which we are subject, including, but not limited to, AML and CFT requirements;
Processing is necessary for the purposes of the legitimate interests pursued by us. We are processing Personal Data for purposes set forth above under legitimate interest. As part of this, we must maintain and develop our Website, technical systems and IT-infrastructure, technical and organizational solutions that may also use your Personal Data, in order to provide you with adequate Services. We also process your Personal Data for protection of your or another person vital interests;
A consent to the processing of Personal Data. We are processing Personal Data for marketing purpose under a client’s consent, meaning freely given, specific, informed and unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, signify agreement to the processing of Personal Data relating to you;
another basis prescribed by the law.

6. SECURITY MEASURES

Data security is extremely important to us, and we organize and implement all necessary and relevant procedures and technology to safeguard and secure your Personal Data collected by us. Security measures are implemented to protect Personal Data from involuntary or unauthorized processing, disclosure, or destruction.

Personal Data is protected by us by security safeguards appropriate to the sensitivity of the information.

Our security safeguards protect Personal Data against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. The Company protects Personal Data regardless of the format in which it is held.

Depending on the nature of the risks presented by the proposed processing of your Personal Data, we will have in place the following appropriate security measures:

organizational measures (including but not limited to personnel training, policy development, security clearances and limiting access on a “need-to-know” basis);
technical security measures (including but not limited to physical protection of data, physical measures, encryption, passwords); and
securing ongoing availability, integrity, and accessibility (including but not limited to ensuring appropriate back-ups of Personal Data are held).

We ensure that the above measures provide a level of security appropriate to the special risks that exist in the processing of the Personal Data and the nature of the Personal Data being processed.

Unless we are required or permitted by law to do so, and subject to our relevant third-party business relationships (our partners, service providers, contractors, agents, financial institutions, social media etc.), we will not disclose your Personal Data to any irrelevant third parties for security purposes.

We also restrict access to Personal Data to just those personnel, contractors, advisors, and auditors who need it to perform their job or service tasks. Personal Data is only accessible to our personnel and contractors that require it for their work. We conduct periodic evaluations to verify that appropriate information processing rules and procedures are understood and followed. All of our physical, electronic, and procedural precautions are intended to follow applicable laws and regulations.

To utilize all of the features and functions of our Website, you may be asked to submit certain Personal Data, including your password(s). You are responsible for keeping your password(s) confidential and secure.

While we strive to protect your Personal Data, please keep in mind that the transfer of any information over the Internet is not completely secure and is done at your own risk and discretion. We cannot, therefore, guarantee the security of your Personal Data transmission to our Website when it is outside our reasonable control.

While there is an inherent risk in sharing data over the Internet, we have implemented suitable security measures to protect your Personal Data from being mistakenly lost, used, damaged, or accessed in an unauthorized or unlawful manner, altered, or disclosed.

7. PERSONAL DATA SUBJECT RIGHTS

We need to make you aware of your rights. The rights you have depend on the reason we are processing your Personal Data.

Right to Access – right to ask us to provide a copy of Personal Data which we process, access to your Personal Data, which enables you to obtain confirmation of whether we are processing your Personal Data. You have the right to request the following additional information concerning your Personal Data:
- the purposes of the processing;
- the categories of Personal Data concerned;
- the recipient(s) or category(ies) of recipient to whom/which Personal Data have been or will be disclosed;
- the source from which the Personal Data is being collected;
- the recipients of classes of recipients to whom they are or may be disclosed;
- the criteria determining the period for which Personal Data will be stored etc.

Unless otherwise set forth by the law, within 30 days upon your request, we provide you with the copy of the Personal Data which we process.

Right to Rectification – you have the right to ask us to rectify Personal Data in case the data is incorrect, misleading, excessive or incomplete, or not relevant to the purpose for which the Personal Data is held. The Company takes care that the Personal Data that is used on an ongoing basis, including information that is disclosed to third parties, generally be accurate and up-to-date, unless.
Right to Erasure (sometimes called Right-to-be-forgotten) – you have the right to ask us to erase Personal Data, unless we are is obliged to continue processing your Personal Data under law or under an agreement between a client and us, partner and us, or in case we have has other lawful grounds for the continued processing of Personal Data.
- You may amend or remove any portion of your Personal Data at any time by using the Website interface, or contacting or emailing us. Such amendment or removal of certain Personal Data may lead to limiting or cessation of your access to Services.
- Your Personal Data will not be erased immediately; it will be stored at our facility to comply with statutory obligations, AML and CFT requirements. As required by the AML and CFT requirements, we must store any collected information within a fixed term from relationship termination. This period may be further extended in certain cases if so provided by and in accordance with the applicable legislation. Biometrics is processed and stored so long as the other Personal Data as set forth in this Privacy Policy. Your Personal Data will be removed from our records after this period has passed.
Right to Restriction – you have the right to ask us to restrict the processing of the Personal Data in case the data is incorrect or incomplete or in case Personal Data is processed unlawfully.
- Upon amendment or removal of your Personal Data, it is archived and safekept separately from processed Personal Data. Such restricted Personal Data is processed purely for storing purposes and cannot be accessed automatically or by unauthorized personnel. Restricted data may only be used or restored only in select ways prescribed by law or legal proceeding. Upon expiry of storage term, restricted Personal Data is deleted.
- Your Personal Data is stored for as long as their storage is required for appropriate purposes for the processing of Personal Data, as well as in accordance with the applicable laws (including but not limited to AML/CFT laws). Personal Data may be stored in an electronic form and/or in paper format, provided always that your Personal Data will be stored securely and protected against unauthorized or unlawful processing and against loss or destruction, using appropriate technical and organizational measures. When assessing the length of the storage of Personal Data, we take into account existing regulatory requirements, aspects of contractual performance, your instructions, and our legitimate interests. If your Personal Data is no longer needed for the purposes specified, we will delete them or destroy.
Information Availability – you have the right to receive Personal Data concerning you provided to us, in a structured, commonly used and machine-readable format. We are obliged and have provided all the information which you have right to receive.
Right to Data Portability – you have the right to ask us to provide you or, in case it is technically feasible, a third party, your Personal Data, which you have provided to us and which is processed in accordance with your consent or an agreement between you and us. Note that this right only applies to the automated information which you initially provided consent for us to use or where we used the information to perform an agreement with you.
Right to Object – you have the right to object to processing your Personal Data in case there is a reason to believe that we have no lawful grounds for processing the Personal Data and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your Personal Data which override your rights and freedoms.
Right to Withdraw Consent for Data Processing – you have the right to withdraw the consent granted for the processing of Personal Data at any time. Withdrawal does not affect the lawfulness of the processing conducted before the withdrawal. If you withdraw your consent, we may not be able to provide certain Services to you, but we will advise you if this is the case at the time you withdraw your consent.
Right to File a Complaint – you have the right to file complaints regarding your Personal Data. In addition, you have a right to lodge a complaint with the respective supervisory body.

8. TRANSFER OF PERSONAL DATA TO THIRD PARTIES

We may transfer your Personal Data to the following third parties:

Regulatory authorities to whom we are obligated to disclose your Personal Data under the law, AML and CFT requirements; agencies that deal with law enforcement; entities in cases of fraud or collusion prevention, identity verification, payment processing, credit reference; banks/financial institutions; courts;
Our related entities, personnel, officers, agents, contractors, designated representatives, other companies that provide services to us, other third parties to satisfy the purposes for which the information was collected or for another purpose, if that other purpose is closely related to the primary purpose of collection and a natural person would reasonably expect us to disclose the information for that secondary purpose;
Third parties who help us analyze the information we collect so that we can administer, support, improve or develop our business and Services we provide;
Identification and verification service providers engaged by us for your verification, performance of AML and CFT requirements, as well as other software service providers who assist us to provide Services;
Our professional advisers such as consultants, bankers, professional indemnity insurers, brokers and auditors so that we can meet our regulatory obligations, and administer, support, improve or develop our business;
Server hosts, which store our data, communication service providers, which help us stay in touch with you;
Third parties, including those in the fintech, brokerage industry, marketing and advertising sectors, to use your information in order to let you know about services which may be of interest to you in accordance with the Applicable Legislation;
Banking, financial service providers;
Debt recovery agencies who assist us with the recovery of debts owed to us;
To facilitate the sale of all or a substantial part of our assets or business or to companies with which we propose to merge or who propose to acquire us and their advisers; and
Other third parties which services, facilities we use, in order to provide our Services and deal with certain processes necessary for the operation of the Website, perform internal procedures and law requirements.

We have taken steps to guarantee that third parties which process your Personal Data have appropriate technological and organizational safeguards in place to secure this Personal Data, and we will also ensure that they are compliant with the Applicable Legislation. We have taken precautions to guarantee that third parties contracted by us preserve the confidentiality and security of Personal Data, and that Personal Data is handled exclusively for the purposes set forth in this Privacy Policy.

Personal Data shall not be processed (or cause to be processed) in a country that has not been designated by the European Commission as providing an adequate level of data protection unless it has put in place such measures as are necessary to ensure such transfer is in compliance with personal data protection laws, except where otherwise required by applicable law. However, when collected Personal Data is transferred outside of the EEA, we must guarantee that the appropriate safeguards, such as standard contractual clauses and data processing agreements, are in place.

On our Website we include or may include references or links to third-party websites. External links can be clickable text, banners, or picture connections to other websites, with no restrictions. We have no control over outbound websites and are not responsible for their content, terms of service, or policies. This Privacy Policy applies only to this Website and does not cover your use of other websites, including those of our partners and service providers, social media, and so on. We recommend that you review the privacy policies of other websites before using them.

9. PERSONAL DATA USE IN COMMUNICATION AND MARKETING

We may contact you via phone, email, SMS, or push notification to advise you about current and new Services, partnership conditions that may be of interest to you.

We shall guarantee that any email we send as marketing conforms with the Applicable Legislation, proper regulation of the Comoros, and includes an ‘unsubscribe’ button so that you may opt out of any future marketing communications. You can deny marketing messages delivered via push notifications by declining the applicable permission in your phone or tablet settings, but this will prevent you from receiving further messages from us via push notification. You may also opt out of receiving marketing communications from us by using the contact information provided below.

You can also contact us and request that your information be removed from our marketing list. We will make every effort to remove your information from our marketing list within a reasonable time frame.

Our marketing list may be managed by software and servers located overseas, and your Personal Data may be transported overseas as part of our marketing efforts.

We will also send communications that are required or necessary to send to users of our Website, that contain information about important changes or developments to or the operation of the Website, or as well as other communications you request from us. You may not opt out of receiving these communications but you may be able to adjust the media and format through which you receive these notices.

Where we receive your request to stop the marketing, we must, where the Personal Data are kept only for the purpose of direct marketing, as soon as reasonably practicable and in any event not more than 30 days after the request has been received, erase the Personal Data, or must not process the Personal Data for direct marketing after the expiry of 30 days.

10. HOW LONG DO WE STORE PERSONAL DATA

We store Personal Data within the term of its processing by us, third parties engaged by us for Services providing, and additionally 5 years, or 7 years in some cases (unless a longer term is prescribed by the Applicable Legislation) after termination of a business relationship with the client, partner, other cases set forth in the law, unless longer term is required by the applicable law.

11. COMPLAINTS AND REQUESTS

If you have any queries in relation to this Privacy Policy, you wish to access or correct the Personal Data we hold about you, or make a complaint, please contact us at:

Email: [email protected] (our Data Protection Officer being authorized officer).

We aim to resolve all complaints as soon as possible. Where we cannot resolve a complaint within that period, we will notify you of the reason for the delay as well as advising the time by which we expect to resolve the complaint.

In order to disclose information to you in response to a request for access we may require you to provide us with certain information to verify your identity. The Applicable Legislation may prescribe exceptions which may affect your right to access your Personal Data.

If you believe that there has been a breach of the Applicable Legislation, we invite you to contact us as soon as possible.

If we become aware of a security breach, we may seek to notify you electronically so that you can take appropriate preventive measures. If a security breach occurs, we may make a notice on the Website.

When Personal Data breach is anticipated to result in a high risk to clients, your rights and freedoms, we will inform you.

If you are not satisfied with our handling of a complaint or the outcome of a complaint you have the right to lodge a complaint with an appropriate authority.

Should we lawfully receive your Personal Data from a third party, you will have the same rights regarding information in question as related to information you provided to us directly or we have collected during cooperation with you.

12. COOKIES

Our Website uses Cookies (“Cookies”), small text files saved to your computer or device in order to customize and improve your experience while visiting and using our Website. We establish constant Cookies for statistics conducting; also, it gives the chance to us to trace and designate our Website and interests of our users and to improve experience of granting of our Services on the Website. Our Website uses a Cookies choice reservation allowing you to accept/enable or refuse/disable the use and saving of our Cookies on your computer or another usable device.

13. CHANGES TO PRIVACY POLICY

Our Privacy Policy is reviewed and updated on a regular basis to ensure that any new obligations and technologies, as well as any changes to our business operations and practices, are taken into account, as well as that it remains abreast of the changing regulatory environment. Any Personal Data we store will be subject to our most recent Privacy Policy.

If we decide to update our Privacy Policy, we will post those changes here and other places we deem necessary.

14. DEFINITIONS

The following terms has the meaning as defined below:

Data Controller of your Personal Data means a legal entity that determines the purposes, conditions and manner of any processing activities that it carries out.
Direct Marketing means a communication, by whatever means, of any advertising or marketing material which is directed to particular individual.
GDPR means the General Data Protection Regulation (EU) 2016/679, of the European Parliament and of the Council of 27 April 2016 On the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC, as amended, replaced, or superseded and in force from time to time, and as transposed into member-state legislation.
Personal Data means any information which relates to an identified or identifiable natural person. An identifiable person is one who can be identified directly or indirectly in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. It does not include data where the identity has been removed (anonymous data).
Services encompass the services that the Company identifies as being covered by the Company via the Website.

1 . Anti-Money Laundering (AML) policy

The Anti-Money Laundering (“AML”), counter-terrorism financing (“CFT”) and know your client (“KYC”) Policy (the “Policy”) is developed and implemented by the following companies of the Otet Group:

1. Otet Group Ltd., a company duly incorporated in Saint Lucia, registration No. 2023-00595, being a brokerage company,

2. Otet Group LTD, a company duly incorporated in the Comoros Union (Mwali), registration No. HY00523012, holding a valid Brokerage License No. T2023304 issued by M.I.S.A. Ltd.

(each hereinafter referred to as the “Company” or “we” or “our” or “us”).

Each Company is working hard to create a culture that helps to detect and report any incidences of money laundering and/or terrorist financing. Each Company is committed to be in compliance with all applicable laws and regulations regarding anti-money laundering and terrorist financing in the jurisdictions where it is registered.

2. Money Laundering and Terrorist Financing

The proper AML/CFT measures and processes are designed and implemented by each Company. So, each Company:

1. Identifies and verifies each client, designated representatives, beneficial owners;

2. Maintains record keeping procedures in accordance with applicable laws and regulations;

3. Applies appropriate internal controls and communication, ongoing monitoring of clients, their transactions;

4. Has put in place a robust governance framework for managing risks and AML/CFT compliance, including proper internal AML/CFT and KYC policies and procedures;

5. Has appointed an experienced and independent Money Laundering Compliance Officer (MLCO);

6. Has proper training programs for current and new employees (AML training as part of new employees onboarding, and annual AML/CFT and KYC trainings). Employees with direct AML/CFT and KYC responsibilities participate in additional specialized training programs;

7. Implemented other processes and measures as required by the applicable AML/CFT regulations and laws.

3. KYC and Due Diligence Procedures

The Company identifies and verifies the identity of all clients, regardless of whether they are engaged in an ongoing business relationship or a one-time transaction, and whether they are a natural person, legal entity, or legal arrangement. Within the verification process the reliable and proper documents, data, or information are used. Additionally, the Company checks that any representative acting on behalf of a client is properly authorized, and verifies the identity of such representative.

The Company identifies the beneficial owners and takes reasonable measures to verify the identity, using the relevant information or data from reliable sources to ensure accuracy and confidence in the identification process. Please note that the Company could ask a client to provide copies of documents, fill in the forms, and questionnaires as required, and the client is obliged to provide them all.

The Company conducts a thorough risk assessment of its client relationships to identify and evaluate potential risks. This assessment takes into account various factors, including the nature of the relationship, the services provided, the client’s location, and the industry or sector in which the client operates etc. The Company applies a risk-based approach to its AML/CFT compliance processes, allowing for the application of stricter measures for higher-risk relationships and more simple measures for lower-risk ones.

The Company could implement a simplified or enhanced due diligence. The simplified due diligence (SDD) is allowed where a risk assessment confirms a lower risk of money laundering or terrorist financing. The enhanced due diligence (EDD) is applied in case of a higher risk of money laundering or terrorist financing and, in particular, in case of clients coming from or based in a high-risk third country or engaged in high-risk business activity. The criteria of clients for the EDD are defined by internal AML/CFT policies and regulations of Company, applicable legislation.

The Company complies with the domestic legislation, but also implements stricter rules for AML/CFT procedures. The Company remains committed to maintaining proper AML/CFT procedures in order to ensure transparency, integrity, fairness, always prioritizing the best interest of the clients.

Clients must provide accurate and up-to-date information and documentation.

The Company reserves the right to request photo or video verification of the client, their representatives, and beneficial owners.

If a client’s identification information changes or if their activities raise suspicion, the Company reserves the right to request updated documentation, even if previous verification has been completed.

4. PEPs, Sanctions screening

The Company identifies and verifies each client’s identity, including determining if the client is a Politically Exposed Person (“PEP”), a close associate of a PEP, or a PEP’s family member. Any relationship with a PEP is automatically considered high-risk. Identification of PEP status is based on the client’s self-declaration before accessing the Company’s services, as well as ongoing verification of this information. Clients are required to declare that they do not hold such a position.

The Company is responsible for ensuring that it does not conduct business with individuals or entities subject to sanctions laws. To fulfill this responsibility, the Company implements screening procedures for all clients against applicable sanctions lists. This process includes verifying the names of individuals and entities against lists maintained by government agencies and international organizations that identify those subjects to sanctions, embargoes, or other trade or financial restrictions.

The Company also screens transactions to ensure they do not involve sanctioned individuals or entities.

Furthermore, the Company has procedures in place to investigate and report any potential violations of sanctions laws to the appropriate authorities.

5. Ongoing Monitoring

The Company also collects information on the purpose and intended nature of any business relationship, and implements ongoing due diligence, monitoring throughout the relationship, including:

1. Scrutinizing transactions conducted during the business relationship to ensure they align with the Company’s understanding of the clients, their business activities, and risk profile, including, when necessary, verification of the client’s source of funds; and

2. Maintaining up-to-date records, ensuring that all documents, data, or information collected during the client due diligence process remain updated and relevant. This involves reviewing existing records at suitable intervals, with particular focus on cases where client due diligence measures were previously conducted, especially for higher-risk client categories.

The Company acknowledges the critical role of ongoing monitoring in mitigating risks related to money laundering and terrorist financing. To ensure that clients do not present high-risks risks, the Company engages in ongoing monitoring of their activities, which includes:

1. Identifying suspicious activity through regular transactions monitoring;

2. Timely updating and reviewing client information for any changes;

3. Conducting EDD when necessary to assess potential risks.

Ongoing transactions monitoring of client relationships involves:

1. Reviewing transactions within the business relationship to confirm they align with the Company’s understanding of the client, the nature and scope of their business, and the associated money laundering and terrorist financing risks;

2. Verifying the source of funds, source of wealth, and assets under the client’s control, when circumstances justify such investigation;

3. Ensuring that all documents, data, or information related to the business relationship are current and accurate, duly recorded.

6. Confidentiality

The personal data we collect is processed in accordance with the Privacy Policy. Please note that the identification process is conducted to comply with the AML/CFT requirements, not because we suspect the Client of any illegal activities.

The Client’s cooperation and understanding of these procedures, as well as the Company’s enquires for documents and information, are essential for effectively combating money laundering and terrorist financing.

Each Company is obliged to comply with AML/CFT and KYC policies and procedures.

All identification documents and services records will be retained for the minimum period of time required by the law, but not less than 7 (seven) years from the relations termination.

This policy is developed to protect both, each Company and the clients. If a client has any questions about the policy, please contact: [email protected]

Client Agreement

Under the terms of a public offer (hereinafter referred to as the “Agreement”), Otet Group Ltd. (hereinafter referred to as the Company), on the one hand, and the natural person filling out the registration form to open trading account with the Company (hereinafter referred to as the Client) on the other hand, collectively referred to as Parties, have concluded this Agreement:

1. General Provisions

1.1. This Client Agreement and its Addendum thereto as well as any information set forth on the official website of the Company, determine conditions of rendering by the Company of services to the Client regarding trade operations in the international exchange market (FOREX) and contracts for difference (CFDs), including all accompanying services and non-trading operations as well as rights and obligations of the Parties arising in connection to the procedure of rendering and execution of such services.

1.2. Services of the Company hereunder are as follows:

a. opening and maintaining Personal Area and trading account(s) of the Client;

b. providing the Client with access to trading platform allowing to obtain information and quotes from the Company, and to perform trade operations;

c. executing trading and non-trading orders of the Client. Trading and non-trading orders execution leads to funds amount change on Client’s account;

d. providing information and consulting services (training sessions and training materials, analytical articles and research, investment and financial advisory services, technical support, etc.). Service shall be considered rendered, if Personal Area of the Client has been registered or any trade or non-trading operation has been processed, including funds crediting to the Client’s account.

1.3. To receive services of the Company the Client is to complete Personal Area registration procedure on the Company’s official web-site: fill in registration form and accept this Agreement. Acceptance of the present Agreement by the Client shall mean that the Client have thoroughly read it, fully understood and agreed with all terms and conditions thereof.

1.4. The Client agrees that the Company has the right to unilaterally amend, add, rename or leave without changes any services rendered under the present Agreement with the notification of the Client within the period and under the conditions provided herein. Any amendments, additions, renaming of the services shall take effect immediately after notification of the Client in accordance with the procedure set forth in Section 3 herein.

1.5. The Client confirms that the present Agreement applies to the services that may be changed, added or renamed in future in addition to those services that are rendered to the Client at the moment of registration and opening of trading account.

1.6. All financial instruments, transactions to which are performed by the Client in accordance with the terms of the present Agreement, are for settlement. Physical transfer of currency or underlying assets (assets in the basis of the contract) does not take place during contract execution.

1.7. With respect to the Client’s trading operations, the Company executes orders, as well as performs transactions contained herein, without providing trust management and without giving recommendations. Information or research materials published on the official website of the Company, or services provided to the Client in any other way, including through the trade copier services, as well as the private opinion or advice of any third party, do not constitute recommendations for any possible trade solutions. The Client is fully liable for all trading operations on his trading account and for his investment decisions.

2. Procedure of Opening of Trading Account

2.1. It is strictly prohibited to open and use more than one trading account with the Company per the same IP address. Each Client is permitted to maintain only one trading account per unique IP address. It is also prohibited to use the same IP address by different Clients. This restriction pertains to the continuous or repeated, one-time use of the same IP address, where even brief terms of using the same IP address are considered a violation.

The Company monitors and tracks IP addresses associated with each Client, different Clients, to ensure the compliance with the restriction mentioned above.

Any detection of multiple trading accounts use under the same IP address will be considered a breach of this Agreement and could result in the following actions that could be taken by the Company, at its sole discretion:

1) Temporary suspension of trading activity on all trading accounts and asking for the clarification,

2) Closure of all the trading accounts, remaining only one,

3) Closure of all the trading accounts,

4) Legal measures, prescribed by the applicable law, as well as where necessary, to recover any losses incurred by the Company due to such violations.

2.2. In order to open trading account in the Company the Client shall take registration procedure on the official website of the Company – fill out registration form for opening of trading account and accept this Agreement.

2.3. When undergoing registration procedure, the Client may select one of several available types of trading accounts offered by the Company. Specific conditions and peculiarities of service rendering for each type of trading accounts offered are available on the official website of the Company and are the integral part of the present Agreement.

2.4. A person who has filled out registration form for opening of trading account shall be deemed individual whose data is specified in such registration form. The Company does not assume any responsibilities for invalidity and/or unauthenticity of the information provided by the Client during opening of the trading account. The Client assumes responsibility for authenticity and validity of the data provided to the Company, as well as for any potential consequences resulting from its invalidity and/or unauthenticity.

2.5. After filling out registration form, confirmation of registration data of the Client and accepting of the present Agreement a trading account will be opened for the Client, and corresponding codes (login and password) are generated and presented to the Client that provide the Client with access to the personal account and Client’s terminal. Access codes (login and password) are used for Client identification during performance of transactions and management of trading account and funds on it. Login is provided once and cannot be changed in future. Password can be changed at any time at the request of either Party. Changing of the password by the Client him/herself can be performed at any time and does not require notification of the Company. When password is changed on the initiative of the Company corresponding notice is sent to the Client’s email address, set forth by the Client as a contact email.

2.6. The Client can open and manage account in USD or EUR at the Client’s discretion. Account can also be opened in other currencies. The Client can find out the list of available currencies on the official website of the Company or by contacting Client support service.

2.7. The Client gets automatically generated Phone Password (code word) after trading account registration. This password is used for identification of the Client, when the Client orders trading operations execution via phone or requests information about trading account balance via phone.

2.8. To confirm request on operation of fund withdrawal from the Client’s account an SMS message with dynamic password will be generated and sent to the Client’s mobile phone that was previously indicated by the Client in the registration form. All requests to withdraw funds from the Client’s account, which are not confirmed by a dynamic password, will be automatically rejected.

2.9. The Client assumes complete responsibility for confidentiality of the credentials of his/her trading account, as well as for any trading and non-trading transactions on the account performed by a person duly authorized within trading platform, on official website or server of the Company using credentials of the Client’s trading account. All messages transferred to the Company by a person duly authorized within trading platform, on official website or server of the Company using credentials of the Client’s trading account shall be deemed issued directly by the Client.

2.10. In case of loss of password by the Client the Company has the right to change existing password at the Client’s request. List of the documents needed for Client’s identification is determined by the Company individually.

2.11. The customer hereby certifies that they are neither a resident nor a citizen of the United States of America, Canada, or Türkiye. The customer acknowledges that if this certification is found to be false, all legal responsibility will be borne by them.

3. Information Exchange

3.1. Labor Hours of the Company: around the clock from 00:00 Monday to 24:00 Friday EET (Eastern European Time: GMT+2 winter time, GMT+3 summer time).

3.2. Labor off Hours of the Company: from 00:00 Saturday to 24:00 Sunday EET (Eastern European Time: GMT+2 winter time, GMT+3 summer time). In addition, the Company’s non-working time include the days of international holidays, entailing the closure of financial markets and stopping the trade of financial instruments, provided in the trading platform. Also, in the event of changes made by liquidity providers, the Company has the right to make appropriate adjustments to the schedule of trading instruments.

3.3. The Company can use following media for communication with the Client:

a. email;

b. internal mail of trading platform;

c. facsimile communication;

d. phone;

e. mail;

f. announcements on the official website of the Company.

3.4. The Company shall use for communication with the Client only those details provided by the Client when opening trading account or changed by the Client later in accordance with the established procedure. Correspondence and information sent by the Company to the particulars set forth by the Client shall be deemed duly sent and the Client does not have the right to refer to invalidity or change of such particulars if the Company has not been notified by the Client beforehand and contact information has been changed inappropriately.

3.5. Any correspondence and information (documents, announcements, notifications, confirmations, requests, reports, messages, etc.) shall be deemed received by the Client:

a. immediately after its sending to the Client’s e-mail;

b. immediately after its sending via internal mail of trading platform;

c. immediately after its sending via fax; d. upon the ending of the phone call;

e. after 7 calendar days from the date of mailing;

f. one hour after publication of an announcement on the official website of the Company;

g. one hour after publication of announcement in Personal Area.

3.6. Correspondence and information sent by the Company to the particulars specified by the Client, namely to Client’s e-mail; specified fax; mail address; via internal mail of trading platform; or publication of the information on the official website of the Company shall be sufficient written notification.

3.7. The Client agrees that the Company has the right to delete messages that are not received by the Client via internal mail of client terminal after three calendar days from the date of sending of such messages.

3.8. The Client agrees that the Company has the right to keep record of oral and phone negotiations with the Client. Such records shall be Company’s property and can be published as evidence of requests and instructions issued by the Client, and other facts of interaction between the Company and the Client, furthermore, records are used for improvement of Client experience.

4. Rights and Liabilities of Parties

4.1. Client has a right:

a. Contact Company or an authorized provider of services of the third party and receive from them quotations and the information with the purpose of making trading transactions in financial markets.

b. Conduct trading transactions in financial markets with the help of the trading platforms (software) provided by Company.

c. Request and obtain from Company any information related to current status of his/her account on the first demand provided that there are technical facilities for communication between Company and Client.

d. At any time to dispose with free money funds on his/her account (with the deduction of credit funds), upon that, this amount shall not exceed balance.

e. Send Company his/her instructions (requests and orders) on trading transactions in financial markets solely with the help of client terminal or over the phone.

4.2. Client guarantees that:

a. He/she has a full legal capacity.

b. He/she has attained majority.

c. He/she has essential authorities to conduct current Agreement, send requests and orders as well as to fulfill their liabilities under the present Agreement.

d. Conclusion of the present Agreement by Client and making (non) trading transactions including other actions under the present Agreement shall not violate any law, regulation and rules applied to Client or under the jurisdiction of Client’s residency. Breach of the present term of the Agreement by Client does not imply any responsibility of Company as well as for the actions arising hereof.

e. Entire information provided by Client under the present Agreement is veracious, accurate and full in all aspects.

f. He/she fully undertakes liabilities and responsibility for all possible consequences which may result from his/her actions under the present Agreement.

g. Client shall be a sole authorized user of Company’s services under a trading account, shall be fully responsible for confidentiality and safety of access details.

h. Client will not use two or more affiliated accounts in the Company registered for other people.

i. He won’t use two or more trading accounts in the Company to open opposite directed trades on the same trading instruments.

j. Client confirms non-criminal origin, lawful possession and right for the funds debited to trading account in Company.

k. Trading systems used by the Clients do not aim at using possible software vulnerabilities.

l. Client’s actions are not aimed at gaining unjustified profit by inflicting loss to the Company, including by using found vulnerabilities, errors and problems of trading platform or Company resources.

m. Client will not use trading strategies that are not economically viable without usage of Company’s promotions and services including Company’s partner program.

n. He won’t use trading strategies, which can lead to the risk of funds losses, exceeding trading account balance.

4.3. Client shall:

a. comply with the terms and fulfill liabilities provided by the present Agreement, Appendixes hereto and in information published on the official website of the Company and specified in this Agreement and Appendixes hereto.

b. pay for Company’s services totally and timely.

c. provide the Company with actual identification information and data, and immediately inform the Company on any changes thereof. The Client shall be responsible for any consequences regarding failure to notify the Company about changes of identification information and data.

d. avoid disclosure of credentials and other information used for Client’s identification for performance of trading transactions and management of trading account and its funds to any third parties.

e. in the event there is a negative balance on his trading account, Client is entitled to depositing his own funds to bring account to zero within 10 (ten) calendar days on Company’s requirement.

f. immediately inform the Company about vulnerabilities, errors and problems in trading platform or on Company’s resources.

4.4. Company has the right to:

a. request a proper fulfillment of the terms hereunder by Client.

b. request from Client provision of data and information required and sufficient for appropriate identification of the Client when opening trading account and performing trading and non-trading transactions by the Client.

c. in case of improper execution by Client of his/her obligations hereunder terminate this Agreement unilaterally and deny access of the Client to the services, provided in accordance with the present Agreement.

d. in order to prevent fraud, money laundering and other conflict situations Company has the right to demand Client’s identification at any time. Client’s identification shall be performed in accordance with the procedure set forth in Section 6 herein.

e. Disable accounts of the Client if he/she connects to the trading server using software of third parties not listed on the Company’s website.

f. Suspend the service or reject providing the service to the Client without giving reason therefor.

g. Continuously monitor all Clients’ transactions related to trading activity for the patterns of market abuse, market manipulation, use of insider information, fraud, criminal activities, or other illegal conduct, as well as monitor that multiple trading accounts do not the same IP address. The Company reserves the right to not process transactions that, in its reasonable discretion, may result in a violation of anti-money laundering regulations, terrorism financing laws, fair market competition rules, or if proper patterns are revealed as set forth above.

4.5. Company shall:

a. Provide Client with capability to perform trading and non-trading transactions in exchange markets under the terms and in accordance with procedures provided herein.

b. Provide services in accordance with the terms of the present Agreement in quality manner.

c. Timely and properly fulfill its obligations hereunder.

d. Take all necessary measures to maintain confidentiality of the information retrieved from the Client.

5. Non-trading operations

5.1. In order to provide the possibility to perform trading transaction the Client shall on his own fund his trading account through the transfer of his own money to the Company’s accounts to the bank details, specified in the personal account. The account can also be credited using all other methods set forth on the official website of the Company and available to the Client from his/her personal account.

5.2. The Client acknowledges and agrees that the Company will not pay the Client any interest for money deposited on his/her trading account, unless otherwise provided by additional marketing activities and services as presented in the website of the Company.

5.3. Withdrawal of available funds from the trading account (excluding credit funds and not exceeding the account balance) can be done by the Client at any moment at his/her discretion, except in the cases specified in this Agreement and its appendices. Requests for withdrawals of available funds from trading accounts are processed on business days and may take between 24 to 72 hours, provided the following conditions are met:

a. The Client has submitted all required KYC items correctly.

b. The trading account has not engaged in any illegal or unauthorized trading activity.

c. The KYC department has revalidated the Client’s identity. This may require the Client to provide additional documentation as required by the AML procedures and processes.

5.4. Account funding as well as withdrawal of funds from the account can be made in USD, EUR and other currencies, list of which the Client can get in the Client Area and by contacting Customer Support Service.

5.5. When funding trading account with currency other than the currency of trading account, the credited money is converted into the currency at the internal exchange rate of the Company. Internal exchange rates of the Company are set at the discretion of the Company depending on market situation, market volatility and other external and internal factors, any references to exchange rates in other sources are unauthorized. Up-to-date internal exchange rates of the Company are published in the Client Area.

5.6. Terms and procedure of funds transfer.

5.6.1. When making operation of funding account in the Company the sender’s data have to completely match with the Client’s data mentioned in the Client Area. In case of revealing the fact of funds transfer from third parties, the Company has the right, but is not obliged to:

• refuse to credit funds;

• block fully or partially the Client’s access to the services of the Company;

• cancel transactions made on the Client’s accounts;

• forcibly return to the sender’s details the balance from the Client’s account, but not more than the amount of the net receipt of funds (the sum of all Client’s deposits minus the sum of all the Client’s withdrawals);

• withhold all costs for the transfers’ refund from third parties.

5.6.2. Funds from the trading account should be withdrawn in the same way and in the same currency to the bank account or electronic payment system with which the deposit was made in a proportional amount. When withdrawing funds, the beneficiary’s data should exactly agree with the Client’s data in the Client area and completely match with the Client’s identity documents.

5.6.3. Depending on the deposit methods used by the Client, the Company has the right to:

• determine at its own discretion by what method and in what currency the Client can withdraw funds;

• reject a withdrawal request indicating in the comment by which payment system and in what currency the Client can create a request to withdraw funds from the trading account;

• Request documents for verification of a withdrawal method proposed by the Company to the Client and (or) to fund a Client’s trading account by using the mentioned method.

5.7. Crediting of funds to the trading account of the Client shall be performed by the Company within one working day from the date of receipt of the money on Company’s accounts or from the date of receipt of order for money transfer between the accounts within the Company.

5.8. The Client can perform funds transfer from his/her trading account to another trading account that belongs to him/her within the Company. Company reserves the right to prohibit internal transfers between Client’s accounts at its sole discretion.

5.9. In case if trading accounts, between which funds are transferred, are handled in different currencies, then currency conversion during the transfer is performed at the internal exchange rates of the Company; information on the current state of such exchange rates is available on the official website of the Company and in the Customer Support Service.

5.10. Withdrawal of funds from the trading account that has open positions can be only performed within the limits of free margin on the account (excluding credit funds and not more than the account balance at the moment of order). If the amount of money withdrawn by the client (including fees, charges and other expenses) exceeds the amount of free margin of the trading account, then the Company reserves the right to decline such an order.

5.11. If Client has open positions involving the instruments on which trading sessions are closed by the moment of handling of the Instruction on withdrawal of money funds, the Company has the right to fully or partly reject such a withdrawal until required trading sessions are opened.

5.12. All withdrawal requests may be confirmed by dynamic password sent in SMS message to the phone number of the Client given in the Client Area. For safety reasons the Company manager has the right to contact the Client by given telephone number for verbal confirmation of withdrawal request.

5.13. All requests for funds withdrawals from the trading account of the Client shall be performed by the Company within the time, specified in the Regulations for non-trading operations.

5.14. All charges and fees connected to the transfer of money and calculations performed by the Parties are paid at the expense of the Client.

5.15. The Client agrees that in case of any failures of the software there may be delays of money crediting to the Client’s trading account. The Company can perform manual crediting of money to Client’s trading account in case of discovering of any failure of software that resulted in delays of automatic money crediting provided that the Client informed helpdesk stuff of the Company about such delay.

5.16. The Client transfers money to the trading account in order to deposit it or to maintain open position at his/her own discretion. The Company does not send any requests to the Client for maintenance of required margin level.

5.17. The Company reserves the right to set limits for minimum and maximum amounts of crediting and withdrawal operations for a period (per once, per day, per month, etc.) for each crediting/withdrawal method. These restrictions shall be published in the Personal area.

5.18. In any cases when the Company has the right to get commission or other fees from the Client for the provided services in accordance with the terms of the present Agreement, as well as the cases when the Client shall indemnify any expenses incurred by the Company, corresponding amount will be deducted by the Company from the trading account of the Client without further authorization.

5.19. The Company is not obliged to disclose or provide information to the Client about fees or other remuneration, and other expenses incurred by the Company from the trading or non-trading transaction of the Client.

5.20. The Company has the right at its discretion and without giving reasons to refuse connecting or to disable promotions and services, to not credit or to deduct from the Client’s account the payments in full under the Company’s promotions and services (bonuses, rewards, prizes, etc.). In particular, if it’s revealed the Client has a trading strategy that is not economically reasonable without the promotions and services offered by the Company, including the Company’s partner program.

5.21. The Company has the right to fully deduct from the Client’s account the payments made under the Company’s promotions and services (bonuses, rewards, prizes, etc.) in case of funds withdrawal from the account by the Client, including funds transfer to another account.

5.22. The Company has the right to:

5.22.1. Block or permanently delete the Client’s account, on which there are no operations initiated by the Client for more than 30 (thirty) calendar days in a row from the moment of opening the account (deposits, withdrawals, trading operations).

5.22.2. Fully deduct from the Client’s account the payments made under the Company’s promotions and services (bonuses, rewards, prizes, etc.) in case there are no operations initiated by the Client for more than 30 (thirty) calendar days in a row (deposits, withdrawals, trading operations).

5.22.3. Charge a monthly commission in the amount of 1 USD or the equivalent in the account currency for maintaining the Client’s inactive account, on which there are no operations initiated by the Client for more than 90 (ninety) calendar days in a row (deposits, withdrawals, trading operations).

5.22.4. Block the Client’s account, on which there are no operations initiated by the Client for more than 270 (two hundred seventy) calendar days in a row (deposits, withdrawals, trading operations).

5.22.5. Permanently delete the Client’s account, on which there is not enough funds to pay commissions for maintenance of an inactive account.

6. Proof of Identity of the Client and Policy of Money Laundering Prevention

6.1. The “laundering proceeds of crime” (money laundering) in the context of this Agreement shall mean the action aimed at conversion of money and other tangible assets acquired from illegitimate activities (terrorism, drug dealing, illegal arms trade, corruption, human trafficking and others) into the money or investments, origin of which seems legitimate.

6.2. In order to prevent laundering proceeds of crime (money laundering) the Company reserves the right to apply means of internal control and programs for its implementation, and render assistance for international organizations for terrorism financing management.

6.2.1. The Company documents and checks identification data of the Client, and keeps and traces detailed reports on all the transactions performed by the Client.

6.2.2. The Company keeps track of all and any operations of the Clients that may have signs of illegal activity aimed at laundering proceeds of crime, and all operations that were performed under unusual conditions.

6.2.3. The Company does not accept cash as a deposit and does not pay cash under any circumstances.

6.2.4. The Company may refuse processing of operation at any point in case it has sufficient grounds to believe that such operation is somehow related to illegal activities.

6.3. The Client acknowledges that the identification data and information specified by him/her during trading account opening can be used by the Company under the program of prevention of money laundering.

6.4. According to international legislation the Company is not obliged to inform the Client about the fact that the corresponding body is notified about the Client’s suspicious activities.

6.5. The Client agrees that in case the Company has the reason to think that the trading account of the Client is used for money laundering, or that the owner of the account hides and provides misleading identification information and data, as well as in case there is a reason to believe that the transactions on the trading account of the Client have been performed with violation of the present Agreement, the Company reserves the right to suspend all operations on the Client’s trading account in order to conduct all necessary checks (registration data check, identification of the Client, checking of history of non-trading operations and transferring of funds, etc.) until complete explanation of circumstances.

6.6. To comply with recommendations on anti-money laundering, during registration of a trading account by Client and any trading and non-trading transactions, Company has the right to require that submission by Client of two identity and registration proof documents. Moreover, the Company has the right to require Client to submit following documents:

– Photo ID (photo of the Client holding identification document);

– Photocopy of the front of the card used for account funding or that will be used for withdrawals;

– Bank statement clearly indicating the holder of bank card used for account funding or that will be used for withdrawals;

– Photo of the Client on the background of the opened account of electronic payment system; – Photocopy of any other identification document;

– Photocopy of utility bill issued within the last 3 months;

– Notarized copy of any document mentioned above, contact details of a public notary;

– Other required documents. Above-mentioned documents are provided in the form of an electronic copy either a notarized copy required by at the discretion of Company.

6.7. It is preferable to provide documents of international sample in English. If documents are provided not in English, the Company has the right to request translation. The documents should be translated in English, printed and signed by a professional translator and provided to the Company with copies of original documents.

6.8. The Client should provide documents requested by the Company within fifteen working days of receipt of the relevant request, as well as meet the following requirements:

– Photos must be of high quality, color, clear and focused;

– The document text must be easily legible, there should be no shadows and highlights that can complicate the information perception;

– The requested document on the image should be presented in full, including lamination corners or edges, as well as the back side (if it contains your data and not empty);

– Graphic editors cannot be used to correct and process images;

– Photo ID (your photo with an identity document you hold) clearly shows your face and it takes up at least 30% of the photo area; – Proof of address (utilities bill, bank statement, etc.) must be no more than three months old. Photos taken before the request or sent not from the Client’s e-mail may be rejected by the Company.

6.9. The Company has the right to suspend non-trading operations on the Client’s account including withdrawal operations until the receipt of the documents requested for the purpose of Client identification.

6.10. In case of failure to submit the documents within the 15 calendar days from the moment of request, Company has the right to suspend all trading and non-trading transactions on the Client’s account, unilaterally close all open positions at the current market prices and freeze all the assets on the trading account of the Client.

6.11. In case of failure to provide documents within 30 calendar days from the moment of request, this Agreement is considered terminated and the Company has the right to close opened trades of the Client at current market price, block access to the Client Area, block funds, cancel operations and trades on the accounts of the Client and archive account irreversibly.

6.12. The Client is responsible for the authenticity of the submitted documents (its copies) and recognizes the right of the Company, in the event of doubt as to their authenticity, contact the low enforcement authorities of the country of the document issuer to verify the authenticity of the documents. Upon detection of forgery fact or editing of the identification image in graphical editor this Agreement is considered terminated, and the Company reserves the right to attract the Client to account in accordance with the laws of the country of issuer. When the Agreement is terminated in accordance with this paragraph, the Company has the right to close opened positions of the Client at current market price, block access to the Client Area, block funds, cancel operations and trades on the Client’s accounts and archive the accounts irreversibly.

7. Confidentiality

7.1. All information submitted by the Client when opening the account and in the course of further interrelations with the Company, as well as information about credentials, provided to the Client for operation, is completely confidential, unless in this Agreement and its Annexes indicated otherwise, and each Party is responsible for confidentiality and use of such information.

7.2. In the event of the Client making a claim against the Company via publicly available resources, the Company reserves the right to disclose obtained information about the Client to fully and objectively review the situation.

8. Responsibilities of the Parties

8.1. Responsibility of the Company:

8.1.1. In case of violation by the Company of terms hereunder due to circumstances the Company is responsible for which resulted in actual damage to the Client, the Client has the right to claim indemnification of actual damage.

8.1.2. The Company does not recompense short-received profit of the Client including the cases, when the Client had an intention to perform some action but did not perform it due to some reason. The Company does not indemnify any indirect losses and moral damage.

8.2. Responsibility of the Client

8.2.1. The Client assumes total responsibility for all the actions performed by the Client in accordance with the present Agreement.

8.2.2. The Client shall bear sole responsibility for any actions resulting from the use of access codes of Client’s trading account.

8.2.3. In case of violation by the Client of the terms hereunder, responsibility for which is not provided herein, as well as in case of any damage made by the Client to the Company, the Company has the right to write off without further authorization from the Client’s account the amount of money sufficient for indemnification of the damage made, demand lacking money to be credited by the Client to his/her account for indemnification of the damage.

8.2.4. The request of the Company for the crediting of lacking money for full indemnification of damage shall be satisfied by the Client within 10 (ten) working days.

8.3. Violation of the provisions of the present Agreement by the Client committed within validity term of the Agreement shall be accepted by the Company for settlement irrespective of the prescription of its commitment, and for that reason the Company has the right to make claims to the Client within any timeframe.

8.4. The Client accepts and agrees to bear the full risk associated with the termination or suspension of any of electronic payment systems used by the Client. In such cases, the Company has the right to block the withdrawal of funds from the Client’s trading account, to the extent in which this payment system was used to deposit funds within the last six months. The time of blocking of funds is limited to six months or terminates automatically after the resuming of work of the electronic payment system.

8.5. The Parties assume responsibilities in accordance with the present Agreement and other applicable regulation for failure to fulfill and/or for default in performance of the obligation under this Agreement.

9. Force-Majeure

9.1. The Parties shall not be held liable for failure to fulfill and/or for default in performance of the terms and conditions hereunder if such failure and/or default resulted from force-majeure circumstances; that is, such circumstances that the Parties were not able to reasonably prevent or foresee. Such circumstances include, but not limited to: earthquakes, floods, tsunami, other acts of God, industrial disasters, epidemics and epizootics, terrorist acts, riots, acts and actions of governmental authorities, embargoes, wars and military conflicts, or other circumstances occurring against the will of the Parties and usually referred to as force-majeure.

9.2. Circumstances that eliminate liability (force-majeure circumstances), in accordance with this Agreement, also include illegal actions against the Company, its employees and/or property, including hacker attacks and other illegitimate actions in regards to Company’s servers.

9.3. In accordance with the present Agreement force-majeure circumstances also include suspending of operation, liquidation or shutting down of some market, or absence of some event, on which the Company bases quotes, or implementation of limitations or special and unusual trading conditions in any market or in respect to any such event.

9.4. In case of occurrence of circumstances eliminating liabilities (force-majeure) the Company has the right to perform any or several following actions without prior notification of the Client:

a. Increase marginal requirement;

b. Close any or all open positions of the Client at the price that the Company shall reasonably consider fair;

c. Suspend and/or change implementation of one and/or several provisions of the present Agreement and Appendixes hereto for the period of such force-majeure;

d. Perform any other actions (or abstain from performance of any actions) in regards to the Company, Client and other clients, the Company considers it to be reasonable under such circumstances.

9.5. The Party, for which failure to fulfill or default in performance of the terms hereunder was caused by force-majeure circumstances, shall inform the other Party about such circumstances within thirty calendar days from the date of the occurrence thereof.

9.6. The Party that fails to inform the contractor about the occurrence of such force-majeure circumstances does not have the right to refer to such circumstances as force-majeure.

10. Procedure of Dispute Settlement

10.1. Possible disputes and contradictions that arise from the execution of the present Agreement subject to settlement through the negotiations between the Parties.

10.2. In case of any dispute the Client who considers his/her interests to be violated, shall submit a claim to the Company.

10.3. Deadline for a claim:

10.3.1. The claim, submission of which is based on the relation of the Parties in regards to performance of trading transactions in exchange markets, shall be submitted by the Client within three working days from the date of appearance of ground for submission of such claim.

10.3.2. The claim, submission of which is connected with performance of non-trading operations and other reasons, shall be submitted by the Client within 5 (five) working days from the date of occurrence of the grounds for submission of such claim.

10.3.3. Failure to submit a claim by the Client within specified timeframe shall be deemed confirmation of the Client’s agreement with Company’s actions and absence of any disputes and controversies.

10.4. A claim submitted by the Client with violation of stated period shall not be considered by the Company.

10.5. The claim shall be executed by the Client in the form of e-mail and/or via ticket system in the personal account, and sent to the official electronic addresses published on the official website of the Company. Claims submitted in other form (at public Internet resources, by phone, by fax or in any other way), shall not be considered.

10.6. The claim must have following content:

a. Name and last name of the Client;

b. Login for trading platform;

c. Description of dispute.

10.7. The claim submitted on the ground of trading transactions in exchange markets shall include the following:

a. Date and time of occurrence of dispute (trading platform time is used);

b. Ticket (number) of disputable position or pending order;

c. Regulatory document name and number of paragraphs that was violated by the Company according to the Client’ opinion;

d. What actions the Company shall take to satisfy the claim according to the Client’s opinion.

10.8. The claim shall not contain:

a. Emotional evaluation of the dispute;

b. Abusive statements in regards to the Company and/or its employees;

c. Swear words.

10.9. The Company has the right to decline a claim of the Client in case of failure to comply with the terms of execution and sending of such claim set forth in Procedure of dispute resolution section of this Agreement, and if the order under question was performed at the expense of the Company or profit mainly generated with the help of the Company’s funds.

10.10. The Company considers a claim and makes a decision regarding disputable situation within the shortest possible timeframe. In case of availability of all data required for claim consideration term of its consideration shall be:

10.10.1. for the claims based on the trading transactions in exchange markets – ten working days from the receipt.

10.10.2. for the claims regarding other issues – twenty calendar days from the date of receipt.

10.11. In case if the Company has to request additional data and/or documents from the Client for the purpose of consideration of a claim, the beginning date of claim consideration shall be the date of receipt of all requested data and/or documents by the Company from the Client.

10.12. Log file of the server shall be the main source of information during settlement of disputes regarding trading transactions of the Client in exchange markets. Information contained in log file of server supersedes any other arguments during settlement of dispute, including information contained in the log file of client terminal.

10.13. In case the claim is considered to be reasonable settlement shall be performed in the form of compensatory payment credited to the Client’s trading account. The Company does not indemnify short-received profit of the Client including the cases, when the Client intended to take some action, but failed to do so due to some reason. The Company does not indemnify any indirect losses and moral damage.

10.14. In case of making a decision in favor of the Client on the disputable situation the Company shall credit compensatory payment to the trading account of the Client within one working day.

10.15. Peculiarities, specific conditions and possible ways of settlement of disputes regarding trading transactions performed by the Client are described in more details in respective sections of Regulations for performance of trading transactions, which is the Appendix to the present Agreement.

10.16. In case any dispute occurs that is not described herein and in appendixes hereto final decision on such claim shall be made by the Company based on common market practice, internal policy of the Company and Company’s vision of fair settlement of dispute. The Company can also use quotes from any other market maker for the comparative analysis of the quotes.

10.17. In case of failure to come to an agreement in the course of negotiations and/or disagreement of the Client with the decision made by the Company, the disputes subject to submission for consideration in the court of competent jurisdiction in accordance with the established provision of law.

11. Applicable Law and Jurisdiction

11.1. The present Agreement is executed and applied in accordance with legal regulations of the Company’s country of incorporation. In case of any issues that are not provided for in this Agreement the Parties shall be guided by the applicable legal regulations of Company’s country of incorporation.

11.2. All disputes and controversies that cannot be settled through the negotiations between the Parties subject to submission to the court of competent jurisdiction of Company’s country of incorporation.

11.3. The Parties agree:

a. That courts of Company’s country of incorporation have the right of exclusive jurisdiction concerning the present Agreements;

b. That they refuse any protests regarding dispute settlement resulting from the present Agreement in the courts of Company’s country of incorporation;

c. Never to make claims grounded by the fact that such settlements are inconvenient in regards to their location or that they do not have legal force in regards to any Party.

12. Amendment and Termination of the Agreement

12.1. The present Agreement between the Company and the Client becomes effective from the date of opening Personal Area by the Client in the Company and shall remain effective within the uncertain term.

12.2. The Company has the right to unilaterally change and add this Agreement with the necessary notification of the Client about it. Any changes and additions hereto shall become effective on the following calendar day after notification the Client about it, unless otherwise is set forth within the content of such changes and additions or within the content of the notice thereof. Conduction of any trade or non-trading operation by the Client means unconditional acceptance of this Agreement by the Client.

12.3. Each Party has the right to refuse unilaterally performance of the present Agreement with the notification of other Party not less than fifteen calendar days prior to the supposed date.

12.4. In case of breach by the Client of terms of the present Agreement, and in cases set forth by legislation rules, the Company has the right to immediately and unilaterally terminate this Agreement. In this case, if the Client has some open positions at the moment of termination of the Agreement, the Company has the right to close such positions at current market price. Company shall recover the funds remaining on Client’s account to Client or his/her duly authorized representative, but these funds shall not exceed net receipt of funds (the amount of all deposit with deduction of all withdrawals) on accounts of Client. Upon that, Company shall debit remains of funds on Client’s account and won’t recover these funds further.

12.5. The Client agrees that the Company has the right at its own discretion to suspend or deny fully or partially Client’s access to Company’s services with further notification of the Client about it. In this case effect of this Agreement shall be deemed suspended or it shall be deemed terminated from the moment of such suspending and/or cessation of service rendering for the Client.

12.6. The Company has the right without Client’s consent to transfer rights and obligations hereunder and under appendixes hereto fully or partially to a third party provided that such legal successor agrees with the terms and conditions of this Agreement and appendixes hereto. The Client shall be notified by the Company in writing about such transfer of rights and obligations not less than fifteen calendar days before such transfer.

12.7. In case of cessation by the Company of performance regulated by this Agreement the Company shall inform the Client about such cessation not later than one month before. All money on the trading account of the Client shall be returned to him/her after closing of all open positions.

12.8. In case of Client’s death (an individual) the right to request money withdrawal from the trading account of the Client shall transfer to the successors of corresponding priority or heir by will. In this case the right to use trading account of the Client and the right to perform trading transactions in exchange markets is not inherited.

12.9. Cessation of the present Agreement does not cancel obligations of the Parties before each other that occurred earlier out of this Agreement including any obligations regarding open positions, transactions for withdrawal/crediting of money to the trading account of the Client.

12.10. In the event that any provisions of this Agreement shall be determined null and void by a court of competent jurisdiction, this provision is to be regarded as an independent part of this Agreement, and will not affect legal effect of other parts of this Agreement.

13. Appendixes and Information about the Company

13.1. The addendum listed below shall be the integral part of the present Agreement:

a. Addendum No.1 – Terms and definitions

b. Addendum No.2 – Risk disclosure statement

c. Addendum No.3 – Bonus policy

d. Addendum No.4 – Fraud warning

e. Addendum No.5 – Privacy policy

13.2. Information published on the official website of the Company shall also be the integral part of this Agreement.

14. Transaction Request Thresholds in Customer Contract

14.1. If the number of requests sent by the customer to the server exceeds 1,000 transactions within a 300-second timeframe, the trading account will automatically switch to “read-only” mode.

a. In the event that the aggregate quantity of transaction requests surpasses 225 positions within a span of 5 minutes during the trading session, this provision of the customer contract shall become applicable.

14.2. If the number of requests sent by the customer to the server exceeds 10,000 transactions within a 3,600-second timeframe, in that case, the trading account will be blocked.

a. Moreover, should the cumulative quantity of transaction requests exceed 2700 positions within a duration of one hour during the trading session, this clause of the customer contract shall likewise come into effect.

15. Use of Robots with API Integrations and Connectivity

15.1. Acceptance of Policy Regarding Unacceptable Trading Practices

Client acknowledges and agrees to abide by the Brokerage’s policy regarding unacceptable trading practices, including but not limited to actions against side markets of feed price and high-frequency trading (“Unacceptable Practices”). Client understands that engaging in Unacceptable Practices is strictly prohibited and may result in termination of their account with the Brokerage.

15.2. Documentation and Reason of Trade

In accordance with the Brokerage’s policy, Clients utilizing Robots for trading purposes are required to provide additional documentation and reasons for trades executed through API integrations and connectivity. Client agrees to furnish all necessary documentation and explanations as requested by the Brokerage to justify trades made through Robots.

15.3. Termination of Account

The Brokerage reserves the right to terminate Client’s account without prior notice in the event of:

a. Engaging in Unacceptable Practices as outlined in Section 1 of this Agreement.

b. Failure to provide requested documentation and reasons for trades as outlined in Section 2 of this Agreement.

c. Any violation of the terms and conditions of this Agreement or the Brokerage’s policies and regulations.

15.4. Acceptance

Client acknowledges that they have read, understood, and agreed to the terms and conditions set forth in this Agreement, including the policies regarding Unacceptable Practices and documentation requirements for trades made through Robots.

15.5. Investigation, Anti-Toxic Volume Measures, and Termination Clause

a. Should the client-customer engage in trading activities that result in profitable outcomes through the aforementioned methods, the entirety of funds held within the account, excluding the initial deposits, shall be subject to investigation and anti-toxic volume scrutiny. During this investigative phase, the client-customer shall be prohibited from withdrawing any profits derived from such trading activities. Furthermore, these additional funds shall remain non-withdrawable until the completion of the investigation and confirmation of compliance with anti-toxic volume regulations.

b. This clause is enacted to safeguard the integrity of trading operations and to mitigate the potential financial risks associated with toxic volume trading practices. The brokerage shall uphold its duty to ensure fair and transparent trading conditions for all clients, while also maintaining regulatory compliance and protecting its financial interests.

c. By engaging in trading activities with the brokerage, the client-customer hereby acknowledges and agrees to abide by the terms outlined in this clause, and any breach thereof may result in immediate account termination and corrective actions as deemed necessary by the brokerage’s legal department.

d. In the event that the trader (herein referred to as “client-customer”) engages in trading activities and executes positions using toxic volume via API connectivity facilitated by expert readers, resulting in detrimental financial outcomes for the brokerage, the brokerage reserves the right to terminate the client’s account. Upon such termination, the brokerage shall correct the account balance to reflect only the initial deposits made by the trader. This correction shall be executed promptly and without prejudice, pending further investigation and verification by the legal department.

16. Hedging Policy: Guidelines and Prohibitions

In adherence to the Otet Group Ltd Client Agreement, our hedging policy is established to provide clear directives and prohibitions regarding hedging activities within our trading environment. Hedging, the practice of maintaining both long and short positions on the same financial instrument concurrently, is permitted as a trading strategy for clients. This approach offers investors flexibility in managing their investment portfolios and mitigating market risks effectively. However, it is imperative for clients to recognize that hedging with the intent of exploiting price discrepancies or engaging in spread arbitrage is strictly forbidden within our trading ecosystem. Any attempt to do so undermines market integrity and may lead to the immediate closure of the client’s account.

Moreover, clients are explicitly advised against participating in hedging activities across multiple Otet Group Ltd accounts or with other similar evaluation firms. Group hedging, the practice of executing opposing trades on the same asset across multiple accounts simultaneously, is expressly prohibited within our trading environment. While this tactic may seek to capitalize on price fluctuations while minimizing market risk, it conflicts with our commitment to fair and transparent trading practices. Therefore, clients are urged to comply with these guidelines to uphold a level playing field for all participants and preserve the integrity of our trading ecosystem.

In accordance with the Otet Group Ltd Client Agreement, adherence to the established hedging policy is essential for maintaining a fair and transparent trading environment. Any violations of these guidelines will be subject to stringent disciplinary actions, including the potential closure of the client’s account. We encourage all clients to familiarize themselves with our hedging policy and adhere to its provisions to ensure compliance with regulatory standards and uphold the integrity of our trading platform.

17. Prohibition of Latency Trading in Otet Group Ltd Client Agreement

The Otet Group Ltd Client Agreement unequivocally prohibits latency trading, an act that exploits delays in trade execution to gain unfair advantages in the market. Recognizing that such practices undermine the fundamental principles of fair and transparent trading, Otet Group Ltd strictly prohibits any activities associated with latency trading within its trading environment. This includes trading on delayed charts and the utilization of delayed data feeds, which provide traders with an unfair advantage over others. By engaging in latency trading, traders create artificial buying or selling pressure, distorting market prices and disrupting the natural balance of supply and demand.

Otet Group Ltd is steadfast in its commitment to maintaining a level playing field for all traders and upholding the integrity of financial markets. Any violation of the prohibition on latency trading outlined in the Client Agreement will be met with stringent disciplinary measures. These measures may include account termination and legal action to ensure compliance and preserve market fairness. Through these actions, Otet Group Ltd reaffirms its dedication to transparency, fairness, and trustworthiness in the financial markets.

Furthermore, Otet Group Ltd continually monitors trading activities to detect and prevent any attempts at latency trading, market abuse, market manipulation, use of insider information fraud, criminal activities or other illegal activities or other unfair practices, as well as use the same IP address for different trading accounts. Our dedicated team of compliance professionals employs advanced monitoring tools, controls and surveillance techniques to ensure that all trading activities adhere to the highest standards of integrity and compliance. Additionally, we provide ongoing education and training to our clients to raise awareness about the risks associated with latency trading and the importance of ethical trading practices. By fostering a culture of compliance and ethical conduct, Otet Group Ltd aims to promote a fair and transparent trading environment where all participants can trade with confidence and trust in the integrity of the market.

18. Bonus Abuse and Prohibited Trading Practices

Any joint trades on a single symbol or multiple symbols, whether executed in the same direction or in opposite directions, by a single user or multiple users, whether a bonus is involved or not, will be considered a violation of the identification conditions. Such trades, even if executed with a time difference, may be recognized as coordinated activity. The broker reserves the right to take corrective actions, including but not limited to the removal of bonus credits, profits earned, and restriction of related trading privileges.

The identification of user behavior and determination of violations must be conducted by the broker. This means that the broker, based on its evidence and analysis of customer behavior, will determine whether the user has engaged in such activities, including cases involving the use of multiple identity verifications.

By participating in the bonus program, the client acknowledges and agrees to all terms and conditions related to the bonus, as outlined in the Bonus Terms and Conditions Document with the document number: Otet-Bonus VD 10025-69.

19. General Trading Rules of Otet Group Ltd

These rules govern the relationship between Otet Group Ltd as a broker and its users as recipients of trading services, ensuring compliance with the regulations set forth by our licensing authorities. To maintain integrity and adherence to regulatory standards, Otet Group Ltd strictly prohibits any actions that fall into the following categories:

Violations of Licensing Regulations – Any procedures or activities that breach the regulatory requirements set by our licensing authorities.

Violations of Financial Market Rules – Any actions that contradict financial market laws, policies, or ethical trading practices.

Abuse of Broker Services – Any attempts to exploit the broker through technical manipulation or coordinated group transactions aimed at unfair advantages.

Otet Group Ltd reserves the right to take appropriate action in response to any violation of these rules, including but not limited to account restrictions, termination, or the withdrawal of profits obtained through unfair or non-compliant trading activities. In such cases, the withdrawal of any profits generated through unfair or non-compliant trading will not be allowed.

20. Specific Rules for Incentive Plans

All users participating in Otet Group Ltd’s incentive plans must comply with both the general trading rules and the specific terms of each plan.

Key Conditions:

Plan-Specific Requirements & Restrictions – Each incentive plan may include certain eligibility criteria, restrictions, or obligations that must be followed during its activation period.

Binding Acceptance – By participating in a plan, the user automatically agrees to all terms and conditions outlined in that specific plan.

Broker’s Authority – Otet Group Ltd has sole discretion over the implementation, interpretation, and enforcement of the plan’s terms.

Failure to comply with these rules may result in termination of participation in the incentive plan or additional corrective actions.

21. Enhanced AML, Source of Funds, and Large Transaction Review

21.1. The Company reserves the right, at its sole discretion and at any time, to conduct enhanced due diligence reviews in accordance with applicable Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), Know Your Customer (KYC), Source of Funds (SOF), Source of Wealth (SOW), sanctions screening, fraud prevention, and other regulatory or compliance requirements.

21.2. Any single deposit, withdrawal, transfer, or any series of related transactions, including cumulative transaction activity equal to or exceeding USD 10,000 (or equivalent in any other currency) within any rolling thirty (30) calendar day period, may be subject to enhanced compliance review and verification procedures.

21.3. The Company may request, at any time, additional information and supporting documentation including, but not limited to, bank statements, proof of source of funds, proof of source of wealth, tax records, contracts, invoices, beneficial ownership information, banking confirmations, and any other documentation deemed necessary by the Company, its liquidity providers, correspondent banks, payment service providers, compliance partners, or regulatory authorities.

21.4. The Client agrees to provide all requested information and documentation within the timeframe specified by the Company.

21.5. Until the requested information and documentation have been received, reviewed, verified, and approved, the Company reserves the right to delay, suspend, reject, restrict, place on hold, reverse, or otherwise refuse any deposit, withdrawal, transfer, or account activity without prior notice.

21.6. The Client acknowledges and accepts that transaction processing times may be extended beyond standard processing periods due to compliance reviews, banking procedures, correspondent banking requirements, liquidity provider reviews, sanctions screening, fraud prevention measures, regulatory requests, or other investigations conducted by financial institutions or competent authorities.

21.7. The Company shall not be liable for any delay, restriction, suspension, rejection, cancellation, or other action affecting a transaction where such action results from compliance obligations, regulatory requirements, banking reviews, liquidity provider requirements, fraud prevention procedures, sanctions screening, or requests made by competent authorities.

21.8. Failure by the Client to provide the requested documentation or information may result in the suspension of withdrawals, restriction of account functionality, temporary freezing of funds, account suspension, account termination, or any other action deemed necessary by the Company in order to comply with its legal and regulatory obligations.

22. Trading Abuse, Fair Trading and Compliance

22.1. The Client acknowledges, understands, and agrees that the Company provides its services exclusively on the basis of fair, lawful, and legitimate market participation.

22.2. The Client shall not engage in any trading activity that constitutes, or may reasonably be considered to constitute, Trading Abuse.

22.3. For the purposes of this Agreement, Trading Abuse includes, without limitation, any trading activity, strategy, conduct, transaction pattern, or practice intended to obtain an unfair, artificial, manipulative, abusive, unintended, or unauthorized trading advantage, including but not limited to:

22.3.1. Exploiting high-impact news events, abnormal market conditions, price gaps, execution delays, latency differences, quotation errors, temporary market dislocations, or similar market anomalies.

22.3.2. Grid Trading, abusive Hedging, Lock Positions, Mirrored Trading, Coordinated Trading, Copy Trading Abuse, or any similar trading structure intended to circumvent normal market risk, execution principles, pricing mechanisms, liquidity arrangements, or margin requirements.

22.3.3. Exploiting software vulnerabilities, technical errors, platform malfunctions, pricing inconsistencies, execution deficiencies, quote delays, latency, arbitrage opportunities arising from technical failures, or any unintended feature of the Company’s trading environment.

22.3.4. Fraud, market manipulation, collusion, bonus abuse, rebate abuse, payment abuse, account sharing, multi-account abuse, device sharing, IP-related abuse, or any conduct intended to circumvent the Company’s Risk Management, Compliance, Anti-Money Laundering (AML), or Fraud Prevention procedures.

22.4. Where the Company reasonably determines that the Client has engaged in Trading Abuse or otherwise breached this Agreement, the Company may, without prior notice and at its sole discretion, take one or more of the following actions:

22.4.1. Reject, suspend, delay, or cancel any withdrawal request.

22.4.2. Suspend, restrict, or permanently terminate any trading account.

22.4.3. Require additional Know Your Customer (KYC), Anti-Money Laundering (AML), Enhanced Due Diligence (EDD), Source of Funds (SOF), Source of Wealth (SOW), or any other verification required by the Company.

22.4.4. Void, cancel, reverse, deduct, confiscate, permanently remove, or otherwise adjust any trade, transaction, profit, gain, bonus, rebate, commission, promotional credit, account balance adjustment, or any other financial benefit resulting directly or indirectly from Trading Abuse.

22.4.5. Reject, suspend, or delay any payment, withdrawal, transfer, rebate, affiliate payment, or Introducing Broker (IB) commission.

22.4.6. Permanently terminate the business relationship with the Client.

22.4.7. Report the matter to any competent regulatory authority, governmental authority, Financial Intelligence Unit (FIU), law enforcement authority, court, or any other competent authority where required or permitted by applicable law.

22.5. The Client expressly acknowledges and agrees that any profit, gain, bonus, rebate, commission, credit, account balance increase, or other financial benefit derived directly or indirectly from Trading Abuse shall not be considered legally earned profit and shall not be eligible for withdrawal, payment, transfer, or any other financial benefit.

22.6. The Client further agrees that the Company shall have the right to recover, reclaim, offset, deduct, or demand repayment of any amount previously credited, transferred, paid, or withdrawn where such amount is subsequently determined by the Company to have resulted directly or indirectly from Trading Abuse.

22.7. The Client agrees that the Company may rely upon trading records, order history, deal history, server logs, journal logs, MetaTrader records, MetaQuotes identifiers, device identifiers, IP addresses, VPS information, latency measurements, ping records, liquidity provider records, pricing records, execution reports, communication records, payment records, blockchain analysis, account relationship analysis, KYC information, AML investigations, and any other technical, financial, operational, or compliance evidence reasonably available to the Company when making any determination under this Clause.

Amendment Part of the Otet Markets Client Agreement and Terms & Conditions

Amendment to Clause 14.3 · New Clauses 23 to 28 — Prohibited Trading Practices · Account, Transfer & Withdrawal Review · Risk-Management Measures · Account Monitoring · Order Execution · Promotional Credit Administration

This amendment forms an integral part of the Otet Markets Client Agreement and Terms & Conditions. It amends clause 14.3 as set out in Part 1, and inserts new clauses 23 to 28 following clause 22 (Trading Abuse, Fair Trading and Compliance) as set out in Part 2. By continuing to hold an account, transferring funds, or placing any order after the effective date, the Client agrees to be bound by the provisions below. Capitalised terms have the meaning given in the Terms and Definitions document, except where defined in this amendment.

Part 1 — Amendment to Clause 14.3 (Obligations of the Client)

1.1. In clause 14.3 of the Client Agreement, the following provision is deleted in its entirety:

“in the event there is a negative balance on his trading account, Client is entitled to depositing his own funds to bring account to zero within 10 (ten) calendar days on Company’s requirement.”

1.2. and is replaced with the following:

“in the event there is a negative balance on the Client’s trading account, the Client shall, on the Company’s requirement, deposit sufficient funds to restore the account balance to zero within 10 (ten) calendar days of that requirement. This obligation applies irrespective of the cause of the negative balance, save where the negative balance arises from a manifest error, technical failure, or incorrect calculation attributable to the Company.”

1.3. The remaining provisions of clause 14.3 are unaffected by this Part 1.

1.4. For the avoidance of doubt, the obligation in clause 14.3 as amended is an obligation of the Client, and is not a discretion, option, or entitlement exercisable at the Client’s election. Where the account forms part of a coordinated chain, clause 23.6.3 applies to that obligation.

Part 2 — New Clauses 23 to 28

2.1. The following clauses 23 to 28 are inserted into the Client Agreement immediately after clause 22.

23. Prohibited Trading Practices

23.1. The Company provides its services exclusively for genuine, good-faith trading. The Client shall not use any trading strategy, technique, or account structure whose profitability derives primarily from the exploitation of the Company’s pricing, execution, promotions, funding mechanics, or infrastructure rather than from genuine market risk-taking.

23.2. Without limiting the generality of clause 23.1, the following are expressly prohibited:

23.2.1 Exploitation of High-Impact News Events

Trading strategies designed to systematically exploit price gaps, spread widening, execution latency, or liquidity conditions arising immediately before, during, or after the release of scheduled high-impact economic news or unscheduled market-moving announcements, where the strategy’s profitability depends on execution conditions rather than directional market risk. The Company may designate news-event windows during which orders are subject to enhanced review or modified execution conditions under clause 25.

23.2.2 Abusive Hedged and Grid Structures

Position structures — within a single account, across multiple accounts held or controlled by the same person or acting-in-concert persons, or across accounts held at other brokers — that are designed to eliminate genuine market exposure while extracting profit from the Company. This includes, without limitation: (i) simultaneous or near-simultaneous opposite positions in the same or highly correlated instruments; (ii) grid or averaging structures operated without genuine risk controls with the purpose of exploiting stop-out mechanics, negative balance outcomes, or promotional credit; and (iii) coordinated opposite positioning between accounts identified as related by registration data, device, network, or funding source.

23.2.3 Latency and Off-Market Pricing Arbitrage

Strategies exploiting delayed, stale, or erroneous quotations, connectivity or latency advantages, or price discrepancies between the Company’s feed and other pricing sources, including high-frequency round-trip trades whose systematic profitability depends on quote latency rather than market movement.

23.2.4 Manipulation of Margin, Leverage, and Account Funding

Use of deposits, withdrawals, internal transfers, or credit facilities in a manner designed to manipulate margin requirements, exploit leverage tiers, or structure account equity so that losses are borne by the Company while profits accrue to the Client — including rapid deposit-withdrawal cycling, funding patterns inconsistent with genuine trading purposes, and the use of internal transfers to move value generated by prohibited activity beyond the reach of review.

23.2.5 Abuse of Stop-Out and Negative Balance Mechanics

Any strategy or account structure that relies on account stop-out, or on the occurrence of a negative account balance, as a source of value rather than as a consequence of genuine market risk. This includes, without limitation: (i) deliberately allowing one account to be stopped out into a negative balance while a related or coordinated account holds the opposite, profitable position; and (ii) structuring positions or funding across one or more accounts so that adverse outcomes accrue to an account carrying a negative balance while favourable outcomes are retained by the Client on another account.

Nothing in this clause limits the Client’s obligations under clause 14.2, or under clause 14.3 as amended by Part 1 of this amendment, including the Client’s obligation to restore a negative account balance to zero on the Company’s requirement. No provision of this amendment creates any entitlement to negative balance protection, or waives, reduces, or otherwise varies that obligation.

23.2.6 Misuse of Bonuses and Promotional Credit

Use of any bonus, credit, rebate, or promotional benefit outside its intended purpose, including: trading primarily against promotional credit rather than the Client’s own funds in order to extract risk-free profit; withdrawing funds in a manner designed to defeat bonus conditions; coordinating bonus usage across related accounts; and any conduct that converts a non-withdrawable credit into withdrawable funds otherwise than through genuine trading. Volume, rebate, or commission farming through wash trading or minimal-risk trade cycling is likewise prohibited.

23.2.7 Platform and Order-Traffic Abuse

Any use of the trading platform, application programming interfaces, or automated systems (including Expert Advisors) that places an excessive or abnormal load on the Company’s infrastructure or is designed to influence execution or pricing through order traffic rather than genuine trading intent. This includes, without limitation: sustained high-frequency order placement, modification, or cancellation beyond normal trading behaviour; and quote-stuffing or similar techniques.

23.2.8 Copy, Correlated, and Coordinated Group Trading

Replication of a single trading strategy across multiple accounts otherwise than through a money-management or copy-trading program authorised by the Company; and coordinated trading among two or more accounts or persons — whether or not linked by registration data — where the pattern of entries, exits, direction, sizing, or timing indicates a common controller or acting-in-concert arrangement intended to multiply payouts or to implement any practice prohibited by this clause 23. Substantial statistical correlation of trade sequences across accounts may be relied upon by the Company as evidence of coordination.

23.2.9 Related and Coordinated Accounts

Operating, controlling, or coordinating multiple accounts (directly or through nominees) to implement any practice prohibited by this clause 23. Accounts may be treated as related on the basis of, among other things, KYC data, funding sources, device and client-terminal identifiers, IP addresses or network patterns, connection characteristics, and correlated trading behaviour.

23.3 Consequences of Breach

Where the Company determines, acting reasonably and on the basis of its records, that Client activity falls within this clause 23, the Company may, with or without prior notice:

23.3.1. place the account under review and suspend, hold, or reverse any pending internal transfer or withdrawal request, in whole or in part;

23.3.2. cancel or deduct profits, rebates, commissions, or bonuses attributable to the prohibited activity;

23.3.3. void trades executed under prohibited conditions and correct account balances accordingly;

23.3.4. restrict leverage, instruments, order traffic, or execution conditions on the affected account(s);

23.3.5. suspend or close the account(s) and terminate the Client Agreement;

23.3.6. apply the above to any account determined to be related or coordinated under clauses 23.2.8 and 23.2.9.

23.4 Limitations on Deduction

Any deduction under clause 23.3 is limited to profit, rebates, commissions, or credit attributable to the prohibited activity and shall not exceed the net profit so generated, quantified in accordance with clause 23.6 where the account forms part of a coordinated chain. The Client’s deposited principal, net of any deductions properly made under clause 23.3, remains withdrawable.

The limitation in this clause applies to the deduction of profit, rebates, commissions, and credit only. It does not limit, and shall not be construed as limiting, the Company’s right to recover a negative account balance, or any other amount owed to the Company, under clause 14.2, clause 14.3 as amended by Part 1, or clause 22.6.

The Company’s determination is final at the operational level, subject to the review and complaints procedure in clause 24.6.

23.5 Relationship with Clause 22

This clause 23 supplements clause 22 (Trading Abuse, Fair Trading and Compliance) and is to be read together with it. Where the Company makes a determination under clause 22 or this clause 23 in respect of conduct of a kind described in clause 23.2, the limitations in clause 23.4 apply to that determination and to any action taken under clause 22.4 or 22.6 in consequence of it.

23.6 Coordinated Chains

Where two or more accounts are determined to be related or coordinated under clause 23.2.8 or 23.2.9 (a “chain”), the Company may:

23.6.1. quantify the net profit referred to in clause 23.4 on an aggregate basis across all accounts comprising the chain, rather than separately for each account;

23.6.2. set off any credit balance, pending withdrawal, or pending internal transfer on any account in the chain against any negative balance, deduction, or other amount recoverable in respect of any other account in the chain; and

23.6.3. treat each person who controls, operates, or derives benefit from the chain as jointly and severally liable for the aggregate amount recoverable under clause 23.3, clause 22.6, clause 14.2, and clause 14.3 as amended by Part 1.

For the purposes of clause 23.6.3, a person derives benefit from a chain where funds, credit, or value generated by the chain have been transferred to, withdrawn by, or applied for the benefit of that person, whether directly or through a nominee.

Nothing in this clause requires the Company to pursue recovery against every account or person in a chain, and the Company’s election to pursue recovery against one account or person does not waive, release, or otherwise affect its rights against any other.

24. Account, Transfer & Withdrawal Review

24.1 Continuous Monitoring and Pre-emptive Measures

The Company operates ongoing, automated and manual monitoring of accounts for the practices described in clause 23, independently of whether a transfer or withdrawal has been requested. Where monitoring indicates that an account may be engaged in prohibited activity, the Company may pre-emptively restrict internal transfers and withdrawals on that account, and on any related account, pending review. Accounts trading in a manner consistent with the Client Agreement are unaffected and continue to transfer and withdraw normally.

24.2 Review of Internal Transfers (Trading Account to Wallet)

The Client acknowledges that a transfer of funds from a trading account to the Client’s wallet or to any other account is subject to the same compliance and risk review as a withdrawal. The Company may hold or decline such a transfer where the funds include, or may include, profit attributable to activity prohibited under clause 23. The Client agrees that value generated by prohibited activity may be retained on the trading account and adjusted at source before any onward transfer.

24.3 Withdrawal Pre-Processing Review

All withdrawal requests are subject to a compliance and risk review before processing. The review may include, without limitation: verification of identity and payment-method ownership; review of trading activity for conduct described in clause 23; reconciliation of bonuses and promotional credit; assessment of related-account and coordination indicators; and review of connection and platform-usage records. The Company may request additional information or documentation from the Client for this purpose.

24.4 Processing Times

Standard transfer and withdrawal requests are reviewed within a reasonable period from submission. Where a request is escalated for enhanced review, processing may be extended for the period reasonably required to complete the review, and the Client will be notified that the request is under review.

24.5 Outcomes

Outcome	Effect
Approved	The transfer or withdrawal is processed normally.
Approved with adjustment	The request is processed after deduction of amounts referred to in clause 23.3 (e.g. profits attributable to prohibited activity, unearned bonus amounts), subject to the limitations in clause 23.4. The basis of the adjustment is communicated to the Client in writing.
Declined	The request is declined and the Client is notified in writing of the decision and of the applicable Client Agreement provisions.

24.6 Review and Complaints Procedure

A Client who wishes to contest a decision made under clause 23 or this clause 24 may do so by responding in writing to the notification received. The Company will acknowledge the enquiry, register it, and provide a substantive written response within a reasonable period, ordinarily within five (5) business days and, for matters involving multiple accounts or extended trading periods, within ten (10) business days. A Client who does not accept the outcome may request a final internal review by the Company’s Risk & Compliance function. On request, the Company will provide the Client with the Client’s own account records relied upon and the specific provisions of the Client Agreement applied. This procedure does not limit any right the Client may have under applicable law or under the Company’s complaints procedure.

25. Risk-Management Measures the Company May Apply

25.1. To protect the integrity of its platform and to manage risk arising from the practices described in clause 23, the Company may, at its reasonable discretion and on a non-discriminatory basis, apply operational measures to accounts or instruments, including, without limitation:

25.1.1. reducing available leverage ahead of weekends, market closures, or scheduled events carrying elevated gap risk;

25.1.2. applying modified margin requirements or execution conditions during designated high-impact news windows;

25.1.3. limiting order-submission rates or automated order traffic that places abnormal load on the platform;

25.1.4. restricting or adjusting trading conditions on accounts under review under clause 24.

25.2. Such measures are risk-management controls applicable to trading conditions and do not, by themselves, constitute a determination of breach under clause 23.

26. Account Monitoring and Data Use

26.1. In addition to website monitoring, the Client acknowledges and agrees that the Company records and analyses, for compliance, security, fraud-prevention, and risk-management purposes: trading server logs, including order and execution timestamps; login records including IP address, device and client-terminal identifiers; network telemetry including connection latency; funding and balance operations; and promotional credit usage. This data may be used to identify prohibited practices under clause 23, to establish relationships and coordination between accounts, and to support decisions under clause 24. This clause is to be read together with clause 22.7, which sets out the categories of evidence the Company may rely upon in making a determination. Where permitted by applicable law and consistent with the Company’s Privacy Policy, the Company may share limited information with other regulated entities and fraud-prevention bodies for the purpose of preventing and detecting the practices described in clause 23. All personal data is processed in accordance with the Company’s Privacy Policy.

27. Order Execution

27.1 Discretion to Determine Execution Model

The Client acknowledges and agrees that the Company may execute, route, or hedge the Client’s orders on either a principal basis (the Company acting as counterparty) or an agency/pass-through basis (orders transmitted to and hedged with one or more upstream liquidity providers), or a combination of the two, at the Company’s sole and reasonable discretion. The Company may change the execution model applicable to a Client’s account, or to specific instruments within it, at any time and without requiring the Client’s prior consent, by giving notice where required by applicable law.

27.2 Basis for Determination

In determining the execution model applicable to an account, the Company may have regard to the account’s risk profile as assessed under the Company’s internal risk-management procedures and to the Company’s overall risk-management and hedging requirements. A change of execution model under this clause is a risk-management measure and does not, by itself, constitute or imply a determination of breach under clause 23.

27.3 No Disadvantage to Order Execution

A change in execution model under this clause shall not itself result in the Client receiving materially worse pricing than that generally available under the Company’s published trading conditions for the relevant account type and instrument. Any difference in spread, commission, or execution characteristics between execution models is as disclosed in the Company’s trading conditions schedule from time to time.

28. Promotional Credit Eligibility and Administration

28.1 Discretionary Nature of Promotional Credit

Bonuses, credits, cashback, and rebate-program benefits (together, “Promotional Credit”) are provided entirely at the Company’s discretion, subject to the terms of the relevant campaign. Promotional Credit does not form part of the Client’s own deposited funds and is not withdrawable except to the extent, and in the manner, expressly provided by the applicable campaign terms.

28.2 Restriction of Future Eligibility Following a Clause 23 Determination

Where the Company determines under clause 23.3 that an account has engaged in activity prohibited by clause 23, the Company may restrict that account’s eligibility to receive Promotional Credit, participate in campaigns, or take part in cashback or rebate programs, indefinitely or for a specified period, with notice to the Client. This restriction is prospective only and does not affect Promotional Credit already converted into withdrawable balance in accordance with the applicable campaign terms before the restriction takes effect.

28.3 Removal of Unused Promotional Credit During Review

Where an account is placed under monitoring or review under clause 24, the Company may cancel any Promotional Credit on that account that is active, not yet expired, and not yet converted into withdrawn balance, with notice to the Client. This clause applies only to the outstanding Promotional Credit itself; it does not affect the Client’s own deposited principal or any profit already realised and withdrawn from the account.

28.4 Reversal

Where a review under clause 24 concludes without a determination under clause 23, the Company will, on request, reconsider any restriction applied under clause 28.2 and any cancellation applied under clause 28.3, and may reinstate the Promotional Credit or eligibility, at its discretion and having regard to the remaining terms of the original campaign.

Bonus Terms and Conditions Document as: Otet-Bonus VD 10025-69

1. Eligibility for Bonus

Users can participate in Otet Group Ltd’s incentive plans based on the conditions outlined in each plan. To retain the bonus until the withdrawal stage, users must:

Cooperate with the authentication section for verification.

Fully comply with both:

as mentioned on client agreement for clauses:

19. General Trading Rules of Otet Group Ltd

20. Specific Rules for Incentive Plans

2. Bonus Amount and Allocation

The bonus amount and its allocation depend on the specific plan’s conditions. Otet Group Ltd reserves the right to determine the bonus structure and distribution at its sole discretion.

3. Trading Volume Requirements

A user’s trading volume may be considered a violation of general trading rules if it closely mirrors another user’s trades in the same or opposite direction within a short timeframe. Trades and Positions in incentive plans are subject to heightened monitoring.

4. Bonus Duration

The duration of the bonus is specified in the plan’s conditions and may be adjusted slightly due to holidays or group elimination hours.

5. Bonus Abuse & Prohibited Actions

All General Trading Rules and Specific Incentive Plan Rules apply. Any coordinated trading activities (whether in the same or opposite direction) that are intended to exploit the bonus system may be classified as abuse. In such cases, the broker reserves the right to take corrective actions.

6. Bonus Withdrawal Conditions

Bonuses are non-withdrawable and are intended only for trading support.

Any profits generated from the bonus, however, can be withdrawn under standard withdrawal policies.

7. Bonus Changes & Cancellation

The broker may withdraw or cancel bonuses if a user violates any rules. Bonus removal may occur at any time, regardless of market conditions or account status.

8. Bonus Suspension

The broker reserves the right to suspend a user’s bonus if:

Suspicious activity is detected.

The user is deemed a potential risk to the broker.

Past violations suggest a risk of abuse.

The broker is not required to disclose the exact reasons for suspension as part of its risk management measures.

9. Dispute Resolution

In the event of a dispute regarding bonuses, the broker’s decision will be final and binding.

Users may contact customer support for clarification, but the broker maintains sole authority over the final resolution.

To provide transparent and secure financial services, the use of Visa and Mastercard payment gateways on the official Otet Markets website is strictly intended for depositing funds into personal trading accounts on this platform. Use of these services constitutes full acceptance of the following terms by the user.

1. Deposit Terms

Only users who have fully completed the identity verification (KYC) process and have been approved by Otet are permitted to use the payment services.

The bank card used must be registered under the same name as the user’s account on the platform.

Otet may request additional identity and banking documents to verify card ownership if necessary.

Deposit processing may take up to 24 business hours.

Deposited amounts will be automatically converted to the base currency of the trading account (USD or EUR). Conversion rates may include fees.

The minimum transaction amount is $5 and the maximum is $3,000. A processing fee of 6.5% of the transaction amount applies.

Please note that due to security or AML requirements, payment service providers (PSPs) may impose restrictions on the number or volume of transactions. Otet is not responsible for any rejected or delayed transactions in such cases.

2. Withdrawal Terms

Withdrawals to Visa or Mastercard cards are not permitted.

Users may use alternative methods such as bank transfers, digital wallets, or cryptocurrencies.

All withdrawals are subject to strict compliance with KYC and AML regulations and conducted within international legal frameworks.

If the user’s initial deposit was made via cryptocurrency, withdrawals are only allowed via cryptocurrency or digital wallets; fiat withdrawal methods (such as bank transfers) are not permitted.

3. Refund Policy

Refunds are only possible after review and approval by Otet’s finance department.

Funds will be returned solely to the original bank card used for the deposit.

Only unused amounts or failed transactions are refundable; profits or losses from trades are excluded from refunds.

The minimum refund amount is $1 and the maximum is $1,850. A refund fee of 3.7% plus $1 applies.

4. Prohibited Uses

Users are prohibited from using payment services for:

Transferring funds to third-party accounts

Suspicious, illegal, or money laundering-related activities

Using unauthorized or third-party cards

Transactions originating from sanctioned or high-risk countries, including: Iran, North Korea, Syria, Sudan, Yemen, Cuba, Russia, Belarus, Afghanistan, Central African Republic, Congo, Somalia, Lebanon, Venezuela, Iraq

Providing services to users residing in countries subject to regulatory restrictions, such as: United States, Canada (except in specific cases), European Union, United Kingdom, Australia, New Zealand, Japan

5. User Responsibilities

Users must enter payment information accurately and with full consent.

• In the event of chargebacks or suspicious transactions, accounts will be temporarily suspended pending investigation.

• Otet reserves the right to refuse payment services if discrepancies in the information are detected.

6. Security and Compliance

All transactions are conducted through PCI-DSS certified secure infrastructure.

Users’ bank card information is not stored and is used only for transaction processing.

Otet is committed to full compliance with international Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations.

7. Support Contact

7. Support Contact For transaction inquiries or to report issues, please contact support: Email: [email protected]

As a bonus, Otet Group:

1. Otet Group Ltd., a company duly incorporated in Saint Lucia, registration No. 2023-00595, being a brokerage company,

2. Otet Group LTD, a company duly incorporated in the Comoros Union (Mwali), registration No. HY00523012, holding a valid Brokerage License,

(hereinafter referred to as “we”, “our”, “us”) could provide clients with a free of charge access to trading strategies of experienced traders (“Masters”) for copy-trading purposes.

Clients should be aware that we do not provide advisory services and recommendations, intermediary services in advising services, and are not responsible for the actions or strategies, systems of Masters .

Copy-Trading

1) Copy-trading is an approach that enables clients to take decisions to replicate the trading actions of selected Masters’s strategies, by opening and closing positions by clients themselves, when using their trading accounts opened with us.

2) When copy-trading, each client makes a decision which position to open and which not, as well as when to close it.

3) Masters do not receive access to clients’ trading accounts.

4) Our cooperation with clients is founded on mutual trust. The use of copy trading information for purposes other than those directly connected to our brokerage and ancillary services is strictly prohibited. Additionally, clients are expressly prohibited from sharing copy trading information, in any format, with third parties.

Liability for Profit and Loss

1) Clients are solely responsible for their trading decisions and should conduct their own analysis before following any Masters strategies.

2) Clients should carefully assess their financial situation and risk tolerance before engaging in copy trading.

3) CLIENTS SHOULD CAREFULLY CONSIDER WHETHER SUCH MASTERS’ STRATEGIES AND SYSTEMS ARE SUITABLE FOR THEM IN LIGHT OF THEIR INVESTMENT OBJECTIVES, FINANCIAL CIRCUMSTANCES, TOLERANCE TO RISKS AND INVESTMENT EXPERIENCE.

4) Providing access to any Masters’ strategies, systems does not constitute an endorsement or validation of their methods or performance, but rather being a bonus provided to clients.

5) All trading decisions are treated exclusively by clients’ decisions. We shall not bear the responsibility for the losses that could occur.

6) EACH CLIENT SHOULD BE CAPABLE OF BEARING A SEVERE OR FULL LOSS OF THE AMOUNTS INVESTED IN TRADING AS A RESULT OF OR IN CONNECTION WITH USE OF MASTERS’ STRATEGIES.

7) Copy trading does not guarantee any profitability.

Trading Limitations

1) For the purpose of checking, whether Masters’ strategies are suitable individually for a client, it is advisable to copy trade initially for small amounts.

2) It is recommended that clients allocate no more than 10% of their total capital to any single trading strategy, given the inherent risks of the markets.

3) Clients are responsible for regularly monitoring their accounts and the performance of the strategies they choose to follow.

4) If a client feels uncomfortable with any Master’s strategy, it is recommended to skip using it.

5) It is recommended for clients to additionally learn at least basic trading educational materials to understand the risks, techniques, strategies associated with trading.

Risk Acknowledgment

1) Please refer to the Risk Disclosure Statement, Fraud Warning, other documents at our website.

2) Please be aware that the financial and other markets can be highly volatile, therefore, past performance of a Master does not guarantee future results.

3) Engaging in copy trading activities may result in significant financial losses, including the loss of principal.

4) Access to Masters’ strategies does not assure any level of profitability.

5) It is recommended for each client to monitor ongoing available risks and to focus on them when feeling uncomfortable.

Client Decision

1) It is a complete decision and responsibility of each client to determine the risk-reward ratio, risk appetite.

Technical and Software Issues

1) We are also not liable for any losses resulting from technical, software issues, system failures, when clients engage in copy-trading.

Transactions with Third-Party Accounts

1) Clients must use their own accounts for trading activities.

2) Clients are deprived to provide access to their trading accounts to the Masters, their representatives, other third parties.

3) Clients shall avoid being engaged in fraudulent activities, scams, Client Agreement violation, market abuse and other violating activities and tradings, which are associated with the use of Masters’ strategies.The client will also be responsible for any potential losses resulting from these violations suffered by us.

Acceptance

1) By accessing and using Masters’ strategies, clients acknowledge that they have read, understood, and agreed to these terms and conditions.

2) Trading in financial and other markets involves significant risk, therefore it is possible to lose more than a client’s initial investment. Each client shall be sure that he/she/it fully understands the risks involved and seek independent advice if necessary.

Available Funds Withdrawals

1) Clients must be aware that, according to the Client Agreement, the requests for available funds (profit and principal) withdrawals from trading accounts are processed on business days and may take between 24 to 72 hours, provided the following conditions are met:

• The Client has submitted all required KYC items correctly;

• The trading account has not engaged in any illegal or unauthorized trading activity;

• The KYC department has revalidated the Client’s identity. This may require the Client to provide additional documentation as required by the AML procedures and processes.

PARTNERSHIP AGREEMENT

1. General Provisions

1.1 This Partnership Agreement (the “Agreement”) is made and entered into account by and between Otet Companies Group, namely,

• Otet Group Ltd., a company duly incorporated in Saint Lucia, registration No. 2023-00595, being a brokerage company, and

• Otet Group LTD, a company duly incorporated in the Comoros Union (Mwali), registration No. HY00523012, holding a valid Brokerage License No. T2023304 issued by M.I.S.A. Ltd.

(together – the “Companies” and each separately – the “Company”. The reference to “Company” means the reference to any of the Companies) and

• the Partner being an individual or a legal entity that is referring new clients to the Company.

(together – the “Parties” and each separately – the “Party”).

1.2 “Account” means an account (not demo account) opened for a Client referred by the Partner to any of the Companies.

1.3 “Active Client” means a Qualified Client from the Partner’s group who/which makes at least one transaction that meets the requirements of the Partner’s Commission payment, over the last 30 days.

1.4 “Members Area” means the Partner’s page on the Company’s Website.

1.5 “Multi-Level Partner Commission System” means a system in which the Partner is paid a Commission for the referred Client and Sub-Partners.

1.6 “Partner” means an individual or a legal entity referring new Clients to any of the Companies.

1.7 “Partner’s Group” means the Master Partner with all the Sub-Partners referred by the Master Partner and their Sub-Partners.

1.8 “Partner’s Commission” or “Commission” means a commission paid by the Company to the Partner for the referred Qualified Clients under this Agreement.

1.9 “Qualified Client” means an Active Client, which is not blocked, suspended due to fraud, or any suspicious activity, or another reason at the Company’s discretion, who/which opened Account with the Company, passed the Company’s KYC. A Client shall not be treated as Qualified Client any more when the Company, based on the grounds set forth in Otet Terms and Conditions, restricts/blocks providing services to such Client, wholly or in part.

1.10 “Referral Link” means a link to the Company’s Website, which contains the Partner’s ID and is placed by the Partner to refer Clients. A static link should be in the HTML code of the Website and have the class=”Agent ID” attribute. Links generated on the Website dynamically with the help of JavaScript, Flash, or similar technologies do not meet the definition of a static link.

1.11 “Sub-Partner” means a Partner who/which is registered within the Company and listed in the Master Partner’s group.

1.12 “Website” means www.otetmarkets.com.

2. Subject Matter

2.1 Under this Agreement, the Partner intends to refer potential Clients to the Company for the purpose of offering the Company’s services, in accordance with the terms and conditions outlined herein.

2.2 The Company will handle all contractual arrangements directly with the Clients.

2.3 The relationship between the Partner and the Company is non-exclusive.

2.4 The Parties may collect, store and handle any information about referred Clients.

2.5 The Parties agree that none of Parties are responsible, and cannot be held liable for any other business or activity carried out by the other Party, other than those relations set forth in this Agreement.

2.6 The Parties shall act according to their knowledge in executing their obligations and always to the best interest of the other Parties and Clients.

3. The Company’s Rights and Responsibilities

3.1 The Company, at its sole discretion, opens Accounts to the Clients referred by the Partner, provided they meet the criteria and suitability standards, implemented by the Company’s internal rules.

3.2 The Company agrees to accept instructions and orders from the Clients and send the statements of accounts to the Clients referred by the Partner, in line with Otet Terms and Conditions.

3.3 If require by the AML/CFT regulation or internal policies and procedures, the Company reserves the right to ask the Partner to provide reliable, complete, up-to-date and accurate information, documents of the Partner, Clients.

3.4 The Company provides services to the Clients referred by the Partner, in line with Otet Terms and Conditions.

3.5 The Company is entitled to instruct and control the Partner’s activity and approach when implementing the Partner’s functions and responsibilities under this Agreement. The Company provides the Partner with the Referral Link. The Company provides the Partner with a unique identification code (ID) to register Clients referred by the Partner.

3.6 The Company is entitled to request a comprehensive report detailing the Partner’s performance under this Agreement, including the progress and outcomes of the information provided by the Partner to potential Clients.

3.7 The Company is entitled to change unilaterally the type and the amount of the partnership program and the Partner’s Commission in case the Partner fails to fulfill the terms and conditions of this Agreement.

3.8 The Company provides a non-exclusive, non-transferable, non-sublicensable, royalty-free license to the Partner to use the Company’s trading software, forms, literature, newsletters, market reports, and any other informational material (“Intellectual Property”) the Company provides, solely in connection with the exercise and performance of each Partner’s rights and obligations under this Agreement. The Partner shall make any express or implied statement, or suggestion, or use the Company’s Intellectual Property in any manner that dilutes, tarnishes, degrades, disparages or otherwise reflects adversely on the Company, its Intellectual Property, or its business, products or services.

3.9 The Company is entitled to amend, alter the terms and conditions of this Agreement. The Company is entitled to change the Partner’s Commission, if the market or other conditions change. The notice about this will be sent to the Partner via internal messages, email, posting, or as an announcement on the Website, at least three business days prior to the amendments, alterations taking effect.

3.10 The Company, at its sole discretion, may require the Partner to immediately amend or remove any marketing materials and other information posted on the Partner’s website, platforms, in social media etc., if such information is found to be incorrect, misleading, or harmful to the Company’s reputation, business interests, or regulatory compliance.

3.11 Should any Partner’s actions be harmful to the Company’s interests, or might have a negative influence on the Company’s reputation or operations, or raise concerns regarding the Partner’s work ethics, the Company reserves the right to unilaterally terminate this Agreement with an immediate effect.

3.12 The Partner acknowledges and agrees that the Company is entitled to monitor and review all content posted by the Partner on its website, platforms, in social media etc. The Partner shall promptly comply with any requests from the Company to correct or remove non-compliant content and shall indemnify and hold the Company, its affiliates, personnel, owners, agents, consultants, designated representatives, harmless from any losses, damages, or liabilities arising from non-compliant content. The Partner understands that the failure to comply with these obligations may result in the termination of the Agreement with it/him/her.

3.13 Should the Company reveal that the Partner breaches the instructions and requests of the Company, the Company may, at its sole discretion, restrict the payout of the Partner’s Commission and/or terminate this Agreement with an immediate effect, as well as, in case if the Company considers it reasonable, to close all or part of the Clients’ positions, referred by the Partner, if applicable. The Partner acknowledges and agrees that the Company shall not be liable for any losses or damages arising from such closure.

3.14 The Company reserves the right to terminate this Agreement with any Partner unilaterally with a one-month’s early termination notice.

3.15 The Company is entitled, in the event it reveals or suspect any abuse in the trading activity of a referred Client or the Partner, to take any action it deems fit to remedy the situation, including but not limited to, relations termination with such Client of the Partner.

4. The Partner’s Rights and Responsibilities

4.1 The Partner is fully responsible for compliance with legal regulations in their activity and also shall follow all the terms and conditions of this Agreement, as well as the instructions of the Company.

4.2 The Partner shall provide advice, adequate professional help in order to assist in negotiations with referred Clients.

4.3 The Partner, in line with the Company’s instructions, informs referred new Clients about the scope of activity and services of the Company, about the competitive advantage of the Company, as well as provide all necessary information of the Company. The Parties shall keep each other informed at all times of all strategies, developments and discussions relevant to this Agreement.

4.4 The Partner, in line with the Company’s instructions, provides introductory explanations to the referred new Clients on how the Company’s services, Website, software, external interface (if any) work.

4.5 The Partner shall immediately inform the Company of any circumstances that may affect or prevent them from fulfilling their obligations under this Agreement or that may pose any risks to the Company or Clients.

4.6 When performing the undertakings under this Agreement, the Partner shall follow the law’s requirements of the country of their registration or residency, as well as of the country where their activities are carried out for attracting potential Clients to be referred to the Company.

4.7 Upon the Company’s request, the Partner shall provide a detailed report about fulfilment of its/his/her obligations under this Agreement and the progress and outcomes of its/his/her activities in referring Clients to the Company.

4.8 The Partner shall make reasonable effort to uphold the highest ethical and commercial standards. The Partner shall not allocate the Company’s information in Partner’s website, platforms, social media etc. using, or together with any obscene, libelous, defamatory, illegal, or otherwise offensive material or in any context that harms the goodwill or reputation of the Company or that disparages or brings the Company into disrepute.

4.9 The Partner shall keep all the information regarding the Company and its services posted on its websites, platforms, social media etc. accurate and up to date. If the Company determines that any information on the Partner’s websites, platforms, social media etc. is inaccurate or outdated, it may request the Partner to remove or update the content. The Partner must comply with such a request within 2 days of receiving a request from the Company.

4.10 The Partner is deprived to use the Website design and any of its elements, including but not limited to, the Company’s logo, full or partial elements of the Website, without the Company’s.

4.11 The Partner is not authorized to act as an agent, official distributor, designated representative, or perform any other authority in the name or on behalf of the Company. For the avoidance of any doubt, the Partner will not make any recommendation, give advice, accept any commitment or provide warranties, or accept any responsibility on any matter whatsoever for or on behalf of the Company.

4.12 The Partner undertakes not to engage in any activity falling under the illegal financial operations and money laundering, as well as take any actions to preclude any illegal financial operations and money laundering.

4.13 The Partner procures that during the validity period of this Agreement, 2 months before and 2 years after its validity term, Partner shall not advertise the Clients’ direct competitors.

4.14 The Partner shall not interfere with the services provided by the Company to Clients referred under this Agreement.

4.15 The Partner is deprived to take decisions about any services provided by the Company to Clients referred under this Agreement, without the other Party’s consent.

5. The Partner’s Activities

5.1 Referring Clients, which meet the Company’s qualifications and suitability requirements, to the Company.

5.2 Deliver to a Client, and obtain from a Client, and deliver to the Company all documentation and information including, but without limitation, the Client Account Opening Package, notices, and notifications.

5.3 Obtain and verify a Client’s information including, but not limitation, Client details, information of its/his/her reputation, its financial capacity, and trading objectives.

5.4 Fairly and accurately share with a Client the Company’s business description and profile, according to the Company’s instructions.

5.5 Maintain high ethical standard in business practices, and conduct operations in a manner that positively reflects on the Company.

5.6 Comply with any business-related instruction, terms, or requests, the Company provides to the Partner.

5.7 Keep records of all the referred Clients, legal documents, due diligence, KYC reports, or any other information that may arise during business with the Company.

5.8 Authorize the Company to inspect or conduct any due diligence it may require occasionally, without any limitation or means of investigation.

5.9 Notify the Company, orally and in writing, of any Client complaints or pending or threatened action raised against the Company in connection with any alleged errors, technical glitch, corrections, or any other matter related to a Client’s Account.

6. Referred Client’s Right to Change the Partner

6.1 If necessary, the referred Client may choose leave its/his/her current Partner group and move own profile and trading Account(s) to another Partner group. The Company shall not interfere in the Client’s decision.

6.2 To transfer the profile and trading Account(s) to another Partner group, the referred Client shall submit a request to [email protected] or [email protected]. The request shall include the trading Account(s) numbers, if applicable, as well as the new Partner’s ID and the Partner’s account number.

6.3 The Company reserves the right to resolve disputes between the referred Client and the Partner (s).

7. Partner’s Commission

7.1 The Partner’s Commission shall be calculated once a day, only from completed transactions performed by the Partner’s referred Qualified Clients. For the purposes of billing and payment, the Company makes calculations based on the all the numbers of referred Qualified Clients and volumes of completed transactions by them.

7.2 The Partner’s Commission depends on the type and level of the Affiliate Program and is calculated as a percentage of the Company’s revenue earned from transactions of referred Qualified Clients. The Partner’s Commission rates are individual and agreed with the Company.

7.3 The Company is entitled to unilaterally amend the calculation method and amounts, rates of the Partner’s Commission, depending on market and other conditions change.

7.4 In case of increased costs due to hedging the trades of a Client or group of Clients referred by the Partner, the Company is entitled to reduce the size of Commission payments for such referred Qualified Clients.

7.5 In the event of a dispute related to a transaction for which a Commission has been paid, the Company reserves the right to revoke the Commission accrual for such transaction.

7.6 It is the sole responsibility of each Party to determine whether, and to what extent, any taxes apply to any transactions associated with this Agreement and to withhold, collect, report and remit the amounts of taxes to the appropriate tax authorities. The Company does not perform the functions of tax agents in respect of the payments paid to the Partner.

7.7 For the Commission receipt the Partner’s account is opened by the Company. When processing a withdrawal request from the Partner’s account, the Company uses its internal currency rates as of the time of the request processing.

7.8 The withdrawal and transfer of funds from the Partner’s account are available only after the complete identification and verification of the Partner. After the Partner is completely fully verified, its/his/her status will be changed to “Verified” in the relevant sections of the Member’s Area on http://my.otetmarkets.com/profile/verification-of-the-documents/.

7.9 After assessment and verification of the Partner, the Commission Table becomes available to the accepted Partner, and becomes visible at the Partner’s Members Area.

7.10 The Company and the Partner agree that the Commission will be accrued based on the Commission Table made available to the Partner by the Company.

7.11 In the Basic campaign, when the Partner has a minimum number of Clients, namely, one Client, the Partner must have a minimum balance defined by the Company in the Parner’s account and also a minimum of one trade with any lot size and a duration of at least 120 seconds.

7.12 In case of inactivity for two months, the Partner will be downgraded to a lower campaign.

7.13 In case the Client is unable to follow the requirements of a proper campaign for two months, it/she/he would be downgraded to a lower campaign.

7.14 The Partner who/which has passed complete identification and verification shall be entitled to withdraw funds in any payment system available in the “Withdrawal” section of its/his/her Members Area.

7.15 The Partner is charged for all costs associated with withdrawing funds from the Partner’s account unless the withdrawal is made on specific days when the Company can allow free withdrawals with some limitations.

7.16 The Partner bears full responsibility for the completeness, adequacy of all the information in its/her/his instruction/application for the funds withdrawal.

7.17 The withdrawal of funds from the Partner’s account is processed within two business days from when a relevant instruction/application for the withdrawal of such funds has been confirmed in the Members Area.

7.18 If the payment system is temporarily unavailable, the Company has the right to postpone the date of withdrawal until the payment system is restored.

7.19 The Partner shall allocate a portion of its/his/her Commission to the Accounts of the specific Clients the Partner has referred, in accordance with the terms of the “Rebates to client” conditions.

7.20 The Partner shall allocate a portion of its/his/her Commission to the Accounts of the specific Clients referred by their Sub-Partner referred, in accordance with the terms of “Rebates to Sub-Partner” conditions and the Multi-Level Partner Commission System.

7.21 The Partner cannot refer himself/herself/itself to the referred Clients, nor can it/she/he refer relatives or other affiliated parties to the referred Clients.

7.22 The Company reserves the right to reject the Commission payment, if it reasonably believes that:

• Referred Clients open and close trades instantly to generate the Commissions (rebates);

• Transactions are opened and closed solely for the purpose of the Commission;

• Any form of market abuse or market manipulation may have taken place;

• Any transactions are opened and closed in less than or equal to 120 seconds will not be compensated to the Partner;

• Any form of suspicious activity is revealed in the transactions or behaviors of the referred Clients.

7.23 The Company reserves the right to update, cancel the amount of the Commission, or terminate the Agreement with the Partner, if the Company considers, that the significant portion of the Partner’s payment is derived from trading on one account, as well as the total amount of the Partner’s Commission from the trading account exceeds 60% (sixty percent) of total net deposits for that specific account.

8. Settlement of claims and disputes

8.1 In case there is any dispute arising out of or in connection with the fulfillment of this Agreement, the Parties shall do their best to settle such situations by negotiations.

8.2 Prior to submitting any action to the court, the Parties shall undertake to follow the pre-litigation procedure and try to settle a dispute in an amicable way. The requesting Party shall submit the request/complaint within five days of becoming aware, or when it should have reasonably become aware, that its rights were violated.

8.3 In case of violation of the terms and conditions of Agreement, namely, non-performance or improper performance, the guilty Party shall be liable under this Agreement and current legislation, as well as shall compensate the damages suffered by the other Party.

8.4 Under no circumstances shall either Party be liable to the other Party or to any third parties for any indirect, incidental, unintentional damages, including lost profits or lost data, damage to honor, dignity or business reputation caused by the violation of the terms and conditions of the Agreement.

8.5 All requests/complaints shall be sent via the following means: email to the address [email protected], ticket in their Members Area (https://my.otetmarkets.com/helpdesk/create-a-ticket).

8.6 The Partner’s request/complaint shall be reviewed within a maximum ten business days.

8.7 Should the dispute be not settled in an amicable way, it could be submitted to the proper court.

8.8 The Partner acknowledges and agrees that the relations between the Parties are governed by this Agreement. The Partner further recognizes and agrees that any features or functions not expressly detailed in the Agreement and Members Area, shall not form a ground for a claim or cause of action against the Company.

9. Sub-Partner

9.1 The Partner that refers another Partner to its/her/his group, becomes a Master-Partner, while a referred Partner becomes its/her/his Sub-Partner.

9.2 The Partner can be at both levels of the program, acting as both the Master-Partner and the Sub-Partner simultaneously:

• The Partner (Tier 1) who refers another Partner to the Company becomes the Master Partner for the referred Partner, and the referred Partner becomes a Sub-Partner (Tier 2) under the first Master Partner (Tier 1);

• If the Sub-Partner (Tier 2) refers a new Partner to the Company, the newly referred Partner becomes Sub-Partner (Tier 3) under the first Master Partner, and Sub-Partner (Tier 2) becomes the Master Partner for Sub-Partner (Tier 3).

9.3 Both the Master Partner and the Sub-Partner are considered bound by the terms and conditions of this Agreement from the moment they become/accept the Partner role. The Company shall not be liable for any agreements, other arrangements by and between the Master Partner and the Sub-Partner.

9.4 The Master Partner receives the Partner’s Commission from the transactions of the referred Qualified Clients and Sub-Partners, and the Sub-Partner’s Commission – from the transactions of the Qualified Clients referred by their Sub-Partners. The Company covers fully the Master Partners’ and Sub-Partners’ commission.

9.5 The size, portion of the Master Partner’s and Sub-Partner’s Commission falls under the Partners’ Compensation Schedule approved with the Company.

9.6 The Partner needs at least one active referred Qualified Client to be eligible for rebate the Compensation, unless otherwise defined by the Company.

10. Force Majeure

10.1 In case of force-majeure circumstances (blockade, government restrictions, exchange or market rules material change, suspension, market disbursement, war, civil disturbances, earthquakes, strikes, equipment failure, communication line failure, program breakdown, unauthorized access, theft, or any problem, technical or otherwise, or other events or conditions beyond the Parties’ control etc.) which prevent the complete or partial fulfillment by any of Parties of the obligations under this Agreement, the term stipulated for the fulfillment of the obligations shall be extended for a period equal to that during which such circumstances and their consequences will last.

10.2 It is agreed that in case of force-majeure circumstances, the suffering Party will not be held liable for any costs, damages, or losses caused by force majeure events, including but not limited to.

10.3 If the above circumstances or its consequences last more than 3 months, either Party shall have the right to terminate Agreement without compensation for any possible losses and with mutual payment in accordance with Agreement.

10.4 The Party, for which it becomes impossible to meet its obligations under this Agreement, shall inform within 7 days the other Party of the beginning of the circumstances preventing the fulfillment of the Agreement. Certificates issued by the Chamber of Commerce shall be sufficient proof of such circumstances and their duration.

11. Terms and Interpretation

11.1 This Agreement shall enter into force on the date when the terms and conditions of this Agreement are accepted by the Partner, when proper actions are performed by the Partner indicating the Partners consent and desire to perform a Partner’s role, and shall valid for unlimited period, until determined by either Party by giving to the others a 1-month’s prior termination notice.

11.2 In the event of termination of this Agreement for any reason, the Partner shall promptly destroy all of the information and materials the Partner obtained or received from the Company as a result of the relationship created by this Agreement or return them to the Company if requested to do so.

11.3 The Partner acknowledges and confirms that it has read and understood the terms and conditions of this Agreement and agreed on them.

11.4 Waiver. Any failure on our part to enforce the Party’s rights and remedies under this Agreement shall not constitute a waiver of such right or remedy.

11.5 Confidentiality

The Partner agrees to maintain the confidentiality of all Confidential Information received during the course of its business relationship with the Company, both during and after the relationship. The Confidential Information shall cover any information disclosed by the Company to the Partner and unknown to the public (irrespective of its source or form of communication), as well as information of Clients referred by the Company which is treated the Confidential Information owned by the Company.

Confidential Information includes technical, business, operational, legal, marketing, financial, corporate, and any other information that cannot be seen publicly and cannot be obtained by third parties legally from other sources. By default, all the information shared by the Company is treated Confidential Information, given its nature and character, unless otherwise is defined by this Agreement, the Company or by the law.

Confidential information is related to the previous, current, future and proposed business, services of the Company, and its suppliers and clients, and includes, but not limited to, personal data, information concerning development, design details, specifications, vendors / client lists, systemized gathered information for analysis, analysis results, business forecasts, sales, business results, marketing plans and any other similar information or data which is disclosed, business analysis information, proprietary techniques, trade secrets, copyrights, trade secrets, proprietary information, sketches, drawings, models, know-how, ideas, processes, algorithms, software programs, their parts, software source documents, pricing or proposal information.

Confidential Information also includes proprietary or confidential information of any third party that may disclose such information to the Partner. The Partner will not disclose such information to any third party without the prior written consent of the Company. This clause remains valid upon this Agreement termination.

11.6 Severability. Any provision under this Agreement that becomes invalid shall be ineffective to the extent of such invalidity without affecting the remaining terms and conditions.

11.7 Assignment. The Company may assign the rights or delegate the obligations under this Agreement to another Company or to a third-party with written notice to the Partner within 30 days of such assignment. The Partner grants us the right to transfer this Agreement to any successor legal entity. The Partner cannot assign any of its rights or obligation under this Agreement to any third party.

11.8 Headings. The paragraph headings in this Agreement are inserted for description purposes only and are not intended to limit the meaning of any of the terms and conditions of the Agreement.

11.9 Entire Agreement. This Agreement and other contractual arrangements between the Company and the Partner (Commission Table, contractual arrangement set forth in the Members Area) constitute the entire agreement between the Parties. The Companies have made no representations or warranties other than those expressly provided within this Agreement.

In today’s fast-paced digital world, financial fraud and scams can target anyone. Staying informed, alert, and secure is the best protection. Below, we provide essential information and practical tips to help you avoid falling victim to scams.

No Fraudulent Communications

Our Otet Companies Group, namely, Otet Group Ltd., a company duly incorporated in Saint Lucia, registration No. 2023-00595, being a brokerage company, and Otet Group LTD, a company duly incorporated in the Comoros Union (Mwali), registration No. HY00523012, holding a valid Brokerage License No. T2023304 issued by M.I.S.A. Ltd. (together – the “Companies”) , their subsidiaries and affiliated companies, or any of their employees, vendors, owners, agents, designated representatives, will NEVER initiate unsolicited emails, social networks communications or phone calls requesting legal entities or individuals to invest in or trade online in financial instruments, other assets, in any project or transaction, to disclose or confirm personal or financial information, NOR will request from legal entities and individuals to transfer fund to personal accounts not owned by the Companies.

Fake Identities and Investment Advice

In the digital world, scammers, fraudsters often hide behind fake identities. Stay cautious when interacting online, especially with individuals claiming to be investment advisors, celebrities and the like. Be particularly wary of unsolicited investment advice from so-called online “friends”, owners of investment chats in Internet.

Promises of High Returns

Promises of high returns with low risk are a “red flag”. Remember, investments come with risks—guaranteed profits are often a tactic used by scammers, fraudsters to exploit fear of missing out.

Overpriced Assets and Secret Strategies

Many financial instruments, other assets promoted by scammers, fraudsters are overpriced and lack solid justification for their price spikes. Always research thoroughly before investing or consult a licensed investment advisor for professional guidance.

Scammers, fraudsters know how tempting the promise of a “holy grail” trading system can be — one that claims to generate profits around the clock without any risk or losses. A common trick they use is promoting a so-called secret formula or strategy with promises of extraordinary returns.

Our Official Website

Our official website operates exclusively under the domain name https://www.otetmarkets.com, and is not associated with the hosts of any other websites that may appear similar. You may access the Company website by typing the above domain name into the address bar of your browser, or by bookmarking the genuine website, or contact us through official phone numbers mentioned in our website.

To ensure secure access, please type the domain directly into your browser’s address bar, bookmark the genuine site, or contact us through the official phone numbers listed on our website. Please note that the Companies operate solely through this official website. We do NOT have any other websites and do NOT provide services through social networks. If you encounter any cloned or similar websites, do NOT interact with them, but notify us immediately at [email protected] for investigation and appropriate action.

Please note that any websites in Arabic or Persian referencing the name Otet are NOT owned by us and are operated by third parties for marketing and promotional purposes. We are NOT responsible for the content, functionality, accuracy of these websites, NOR do we have control over them. These third parties are NOT authorized to provide brokerage services

Clone Firm Scams

Fraudsters often impersonate legitimate legal entities to deceive individuals into transferring money to their accounts. These scams, known as Clone Firm Scams, may involve the scammer, fraudster pretending to represent a reputable services company, such as the Companies, to gain your trust and access to your funds.

Fraudsters may use:

• a trusted legal entity’s logo, letterhead, or branding;

• emails, calls, or social media interactions to appear legitimate;

• adopt names or addresses closely resembling those of the genuine company;

• share unreal recommendations.

Always confirm the authenticity of requests by contacting the Companies’ official support team. Never share sensitive financial details over unverified channels. If something seems strange, trust your instincts and double-check with us.

Affinity Fraud

Affinity fraud occurs when scammers, fraudsters target individuals by exploiting shared characteristics such as age, religion, ethnicity, sexual orientation, or professional identity. These scammers, fraudsters often pose as members of the same group they are trying to defraud, leveraging the natural tendency to trust people who share common traits or affiliations.

Typically, affinity scams revolve around fake investments or fraudulent misrepresentations about legitimate opportunities. Scammers, fraudsters may falsify key details, such as the investment’s risk, performance history, or the promoter’s background. A significant number of these scams take the form of pyramid schemes, where funds from new investors are used to pay returns to earlier investors, creating a false impression of success. However, these schemes inevitably collapse when the flow of new money stops, leaving most investors with substantial losses.

Contact Us for Support

If you receive any suspicious communications or encounter websites claiming affiliation with the Companies, please email: [email protected] or contact our customer services on the official phone number.

Conflicts of Interest Policy (the “Policy”)

The scope of the Policy is to ensure that the Company complies with all legislative requirements and the internal procedures , and to take all reasonable steps to identify and manage any conflicts of interest that may arise between us and any of our clients or between our clients.

The Company has established, implemented and maintains this Policy which outlines the description of identification, prevention, management and disclosure of the conflicts of interest related to the Company, its shareholders, members of control, as well as managers and employees, tied agents, designated individuals or other relevant persons (each – the “Relevant person”), as well as any person directly or indirectly linked to them by control (each – “Linked person”), as well as the Company’s clients, that arise in the course of providing any services.

1. Introduction

The Policy is developed and implemented proper conflict of interest processes within Otet Group, namely, 1) Otet Group Ltd., a company duly incorporated in Saint Lucia, registration No. 2023-00595, being a brokerage company, 2) Otet Group LTD, a company duly incorporated in the Comoros Union (Mwali), registration No. HY00523012, holding a valid Brokerage License No. T2023304 issued by M.I.S.A. (each above and hereinafter referred to as the “Company” or “we” or “our” or “us”). Conflicts of interests may include any situation where either the Company or an individual is in a position to exploit a professional or official capacity in some way for either corporate or personal benefit.

Situations where conflicts of interest can occur include the following:

• The Company, or a Relevant person, or a Linked person, is likely to make a financial gain,or avoid a financial loss, or receive another kind of benefit at the expense of the client.

• The Company, or a Relevant person, or a Linked person, has an interest in the outcome of a service provided to the client, or of the transaction carried out on behalf of the client, which is distinct from the client’s interest in that outcome.

• The Company, or a Relevant person, or a Linked person, has a financial or other incentive to favour the interest of another client or group of clients over the interests of the client.

• The Company, or a Relevant person, or a Linked person, carries on the same business as the client.

• The Company, or a Relevant person, or a Linked person, receives or will receive from a person other than the client an inducement in relation to a service provided to the client, in the form of money, goods or services, other than the standard commission or fee for that service, non-monetary benefits or services.

• The affected parties, if conflict of interest arises, can be the Company, its Relevant persons, Linked persons, or its clients. More specifically, a conflict of interest may arise, between the following parties:

• Between a client and the Company.

• Between two or more clients of the Company.

• Between the Company and its Relevant person, or Linked persons.

• Between a client of the Company and a Relevant person, or Linked person.

• Between Company’s departments, or Relevant persons, or Linked persons etc.

2. Independence

The following measures have been adopted by the Company for ensuring the requisite degree of independence

• Appropriate internal control measures for the prevention of conflicts of interest, and to ensure control over the timely detection, prevention and settlement of conflicts of interest.

• Measures to prevent or control the exchange of information between Relevant persons engaged in activities, Linked persons, involving a risk of a conflict of interest, where the exchange of that information may affect the performance of such a person’s duties and responsibilities to the Company (ex: Ethical walls, access controls and data segregation, information-sharing protocols).

• Separate supervision of Relevant persons whose principal functions involve carrying out activities on behalf of, or providing services to, clients whose interests may conflict, or who otherwise represent different interests that may conflict, including those of the Company.

• Removal of any direct link between the remuneration of Relevant persons principally engaged with one activity and the remuneration of, or revenues generated by, different Relevant persons principally engaged in another activity, where a conflict of interest may arise in relation to those activities: the remuneration of employees do not relate with clients’ performance.

• Measures to prevent or limit any Relevant person from exercising inappropriate influence over the way in which a Relevant person performs services or activities. Additionally, the Relevant person who decides or influences an individual’s bonus may exert undue influence over that individual’s integrity of judgment.

• Measures to prevent or control the simultaneous or sequential involvement of a Relevant person in separate services or activities such as reception and transmission of clients’ orders and tasks such as portfolio decision making and calculating performance.

• Prevention of persons who are also active outside the Company from having inappropriate influence within the Company in relation to those other activities.

• Whistleblower channels and reporting mechanisms are established within the Company to enable Relevant persons to report instances of inappropriate influence or pressure related to the facts of the conflicts of interest.

3. The Company’s Senior Management is required to

• procure and maintain the proper internal mechanisms preventing behaviors that may result in conflicts of interest or the possibility of conflicts of interest;

• fully engage in the implementation of policies, procedures and arrangements for the identification, management and ongoing monitoring of conflicts of interest;

• adopt a holistic view to ensure the identification of potential and emerging conflicts within and across business lines and to ensure that informed judgements are made with respect to materiality;

• raise awareness and ensure compliance of Relevant persons by ensuring: regular training (including to contractors and third-party service providers’ staff) both at induction and in the form of refresher training; the clear communication of policies, procedures and expectations; that awareness of conflicts procedures forms part of the performance review/appraisal process, and that the best practice is shared throughout the Company.

• sponsor robust systems and controls and effective regular reviews to ensure that strategies and controls used to manage and mitigate risks remain appropriate and effective and that appropriate warnings and disclosures are issued to clients where necessary;

• utilise management information to remain sufficiently up-to-date and informed; and

• support an independent review of the processes and procedures in place.

4. Ethical walls

The Company has constructed adequate Ethical Walls, in accordance with the legal requirements between its departments and has established clear lines of responsibility, in order to avoid the flow of information held by a Relevant person in the course of carrying out a part of its business to be withheld from or used by Relevant persons who are in the process of carrying out another part of its business, as well as Linked persons. In particular, barriers have been established in order the flow of information is restricted between Relevant persons, access has been limited in relation to information and documentation and communication has been restricted between certain Relevant persons during the course of carrying out their parts of business.

5. Disclosure of conflict of interest

When the measures taken by the Company to manage conflicts of interest are not sufficient to ensure, with reasonable confidence, that the risk of damage to clients’ interests will be prevented, the Company will disclose the conflicts of interest to the clients in order to prevent a risk of damage to clients’ interests. Prior to carrying out a transaction or providing an investment or an ancillary service to a client, the Company must disclose any actual or potential conflict of interest. The disclosure will be in sufficient time, in a durable means.

6. Reporting Conflicts of Interest

In the case of identification of a possible conflict of interest, a Relevant person must refer it initially to his immediate supervisor to assist in the assessment of a material risk of damage and send a completed Notification Form together with full details to allow regulatory scrutiny, of:

• corrective and preventive actions;

• how these actions were considered appropriate;

• any conditions imposed; and

• whether there are still ongoing conflicts, how these are being managed and advised to the client

The Company procures confidential reporting channels for Relevant persons, Linked persons to disclose conflicts of interest.

7. Record keeping

The Company maintains up-to-date records, which are regularly monitored and updated, of all situations giving rise to actual and potential conflicts of interests, and of the measures taken to mitigate such conflicts in the relevant situations. . Any conflict of interest shall be reported to the Company’s CEO and Compliance Officer, who shall be responsible for keeping records of conflicts of interest.

8. Policy review and updates

From time to time, the Policy could be reviewed and updated by us. The review includes an assessment of Policy’s effectiveness in preventing and managing conflicts of interest, and any necessary changes are properly made to the Policy to ensure that it continues to meet the needs of clients, Relevant persons.

The Cookies Policy is developed and implemented within Otet Group, namely, 1) Otet Group Ltd., a company duly incorporated in Saint Lucia, registration No. 2023-00595, being a brokerage company, 2) Otet Group LTD, a company duly incorporated in the Comoros Union (Mwali), registration No. HY00523012, holding a valid Brokerage License No. T2023304 issued by M.I.S.A. Ltd. (each hereinafter referred to as the “Company” or “we” or “our” or “us”). Both Companies use cookies on this website. By using our website, you consent to the use of cookies.

Please review our Privacy Policy for additional information on how we process personal data collected from our website visitors and users.

What are cookies?

Cookies are small pieces of text placed on your device when visiting the website, that allow us to track, save, and remember information about your activity on and use of our website. They are information, not programs, thus they cannot contain viruses. They allow us or a third party to recognise you, make your next visit easier and our Services more useful to you, as well as to improve the performance of our website and to collect statistical data.

We have a legitimate interest in carrying out these actions, and we promise that there will be no impact on your privacy. You have the right to withdraw permission or adjust your choices at any time.

How the Company uses cookies

We use both ‘session’ and ‘persistent’ cookies to run our Services. ‘Session’ cookies stay on your device until you stop browsing. ‘Persistent’ cookies stay until they expire or are deleted.

Cookies help us to enable functionality for the provision, protection, and enhancement of our Services, to record your browsing activity, to determine when you are logged in, to keep your data and account safe and secure, to enable adverts and behavioral advertising, to provide mailings, analytics, and research, to monitor statistics data, to retain your preferences and information about your actions, allowing us to improve your usability and to provide you with the best possible experience on our website.

The types of cookies used are as follows:

Strictly Necessary Cookies: These cookies are essential, as they enable you to move around our Services and use their features, such as accessing logged in or secure areas.

Essential cookies: These cookies allow us to authenticate users and prevent fraudulent use of user accounts.

Performance Cookies: These cookies collect information about how you have used the Services. They may also be used to show you have logged in so we can serve you fresher content, or to track aggregate Services usage so we can test new features and changes on the Services. These cookies are often used for load balancing to ensure that the website remains up and running and to improve Services performance.

Functionality Cookies: These cookies allow us to remember your actions, for example how and when you logged in and out; if you choose to block advertisements; the history of Services tools you’ve used. They also allow us to tailor the Services to provide enhanced features and content for you, and to remember how you customised the Services.

Targeting Cookies: These cookies are used to deliver content that is more relevant to you and your interests. This information may be shared with organizations to deliver advertising and help measure the effectiveness of an advertising campaign, or with other business partners to provide aggregate usage statistics and Services testing.

Third-party cookies: Third- party cookies report usage statistics of the Services, or deliver advertisements on and through the Services. Please note that some are essential to our platforms and as blocking them would severely damage performance, no option to opt out is provided.

Choice of Cookies

When you visit our website, you will be prompted to accept/enable or refuse/disable the additional cookies. If you disable the additional cookies, we will continue to use the required cookies to run the website.

To customize your use of our website and enjoy maximum functionality from our Services, we recommend that you accept all of our cookies. Please keep in mind that if you choose to disable cookies, our website will be unable to remember your visit and provide you with the level of convenience that we would want.

Should you have any questions regarding this Cookies Policy, please contact us at: [email protected]

Otet's Rules and Regulations

A guide to OtetMarkets' terms and documents

The complete reference for Otet's documents and policies

OtetMarkets Legal Documents

Important Notes Before You Start

Responsible Use of Services

A guide to OtetMarkets' terms and documents

Terms and Conditions Otetmarkets.com is the official website of the Otet Group: 1. Otet Group Ltd., a company duly incorporated in Saint Lucia, registration No. 2023-00595, being…

Terms and Definitions Abnormal market conditions mean Fast market. Account history means records of completed transactions and non-trading operations on a Client’s trading account. Account type means…

Risk Disclosure Statement 1. The Client hereby acknowledges, represents and warrants that he/she/it has carefully designated a part of his/her/its assets (Owned Capital) as the Risk Capital.…

Privacy Policy This Privacy Policy governs privacy of the clients, visitors, partners, representatives, beneficial owners of clients – legal entities, partners-legal entities (“you”, “your”, “user”) of…

AML & KYC Policy 1 . Anti-Money Laundering (AML) policy The Anti-Money Laundering (“AML”), counter-terrorism financing (“CFT”) and know your client (“KYC”) Policy (the “Policy”) is developed and…

Client Agreement Client Agreement Under the terms of a public offer (hereinafter referred to as the "Agreement"), Otet Group Ltd. (hereinafter referred to as the Company),…

Bonus Terms and Conditions Bonus Terms and Conditions Document as: Otet-Bonus VD 10025-69 1. Eligibility for Bonus Users can participate in Otet Group Ltd’s incentive plans based on…

Visa and Mastercard Payment Terms and Conditions To provide transparent and secure financial services, the use of Visa and Mastercard payment gateways on the official Otet Markets website is strictly intended…

Copy Trading As a bonus, Otet Group: 1. Otet Group Ltd., a company duly incorporated in Saint Lucia, registration No. 2023-00595, being a brokerage company, 2.…

IB Agreement PARTNERSHIP AGREEMENT 1. General Provisions 1.1 This Partnership Agreement (the “Agreement”) is made and entered into account by and between Otet Companies Group, namely,…

Fraud Warning In today’s fast-paced digital world, financial fraud and scams can target anyone. Staying informed, alert, and secure is the best protection. Below, we provide…

Conflicts of Interest Policy Conflicts of Interest Policy (the “Policy”) The scope of the Policy is to ensure that the Company complies with all legislative requirements and the…

Cookie Policy The Cookies Policy is developed and implemented within Otet Group, namely, 1) Otet Group Ltd., a company duly incorporated in Saint Lucia, registration No.…

Important Notes Before You Start

Responsible Use of Services