APPTRADER 1

APPTRADER 2

PRIVACY POLICY, USE OF THE WEBSITE, TERMS AND

CONDITIONS

Trademarks and Intellectual Property Rights

By browsing and using the website, You agree and undertake the following terms

of use that, together with the privacy policy, regulate the relationship of

APPTRADER with You regarding the use of the web site on Your behalf. The terms

" APPTRADER " or "we" or "us" or "ours" refer to the owner of the web site, the

information materials, photographs and other images published on this site, as

well as the graphic processing, are subject to copyright which are published on

this website and are trademarks or registered trademarks. Except in the cases

explicitly provided for in these Terms of Use, you do not have the right to use the

above trademarks, either individually or in combination with other words or

elements of the design.

Modify the Terms of Use of the Website

The contents of the website are for your information and use at all. They are

subject to change without prior notice.

Liability’s limitation

Neither we nor any third party provide a guarantee of the accuracy, timeliness,

performance, completeness or convenience of the information and materials that

are found or offered on the website for any use. By reviewing the website, you

confirm that you are aware that such information and materials may contain

inaccuracies or errors and we explicitly exclude any liability for irregularities or

errors in full, in accordance with the extent permitted by law.

The Company shall not be liable for damages or loss of profits from inaccurate

information published on the site or any of the sites to which it relates or the

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improper perception of the published information as a recommendation for the

realization of an investment, legal advice, and the like.

Under no circumstances will the Company be liable for damages, including

general,

special, direct, indirect, incidental, consequential, punitive, or any what other

damages (including without limitation, loss of profit or termination of activity) of

any kind that arise or are connected in any way with use or inability to use by the

Website Applicant. As well the Company will not be liable for the application of

the Website or any other services through the Website, or as a result of any non-

performance and non-performance by the Company, Force majeure, error,

omission, interruption, defect, delay in activities, computer a virus or a

breakdown of the line or a crash of the system, even if the Company or its

Representatives are aware of the possibility of such damages, losses or costs.

Also, the Company shall not be liable for errors or inaccuracies in the

transmission process of data and/or Orders for CFDs trading or any instructions

from the client/visitor of the site, interference, fraudulent impersonation,

breaking of secret access codes, erroneous recording or transmission of message

or system failure due to force majeure or for whatever other reason which is not

due to breach of the above either by the Company. You are the only legal remedy

for dissatisfaction with the use of this Web site is to terminate the use of the

Website.

Hyperlinks to other Internet resources are at your own risk. The content,

accuracy, opinions expressed, and other links provided by these resources are not

investigated, monitored, or endorsed by the Company.

The Company shall not be liable for any damage that may occur to the hardware

or software of the user that may arise as a result of the use of this website and/or

land or in connection of this website with other websites/hypertext links or

internet resources.

The Company strives to limit to the maximum degree the inconvenience of using

the site. However, we cannot guarantee or be liable if access to information and

their use is aggravated by the incompatibility of computer programs, by technical

errors, and the like.

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Intended Users of the Website

This Website and all information and functionalities contained therein are not

directed at, or intended for distribution to or use by, any person or entity who is a

citizen or resident of, or located in any jurisdiction where, for any reason, such

distribution, publication, availability or use would be contrary to any applicable

law or regulation. The users of the website need to have an age of 18 years old or

older.

Links to other websites

The Company offers links to other third party websites that may be of interest to

our website visitors. The links provided in our website are provided solely for your

convenience and may assist you in locating other useful information on the

Internet. When you click on these links you will leave Apptrader website and will

be redirected to another website. These websites are not under the control of

Apptrader.

The Company is not responsible for the content of linked third party websites. We

are not an agent for these third parties nor do we endorse or guarantee their

products etc. We make no representation or warranty regarding the accuracy of

the information contained in the linked websites. We suggest that you always

verify the information obtained from linked websites before acting upon this

information.

The cookies

The cookie is a small file placed on the hard disk of your computer. Most web

pages

use cookies. We use cookies to track your use of the Web and provide you with a

more personalized experience and get started with using the services

automatically when you visit the website again.

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The cookies used by the Company are not related to personal data.

Like most web pages, we automatically collect certain information and keep them

in log files. This information may include Internet Protocol (IP) addresses, browser

type, ISP, referencing / exit pages, operating system, data / time printing and / or

data on the number of clicks.

We combine these automatically collected recorded information with others

information we collect for you. We do this to improve the services we provide we

offer, improve the marketing, analytics or the functioning of the Web the page.

The company uses cookies or similar technologies to analyze trends,

administering the Web site, tracking the movement of users across the web the

site and to collect demographic information for our customer base in integrity.

You can visit http://www.aboutcookies.org/ if you would like to receive more

detailed information about cookies and their functionality

Privacy: our commitment

Considering that the privacy and security of your data is of the utmost

importance,

we have implemented technology and security policies, rules and measures for

protection of personal data.

We are committed to taking all reasonable steps to protect your personal data

during transmission and reception.

Use and protection of Personal data

In order to prevent unauthorized access and abuse of personal data, in the

Company all appropriate legal technical and organizational measures are taken to

ensure secrecy and protection in the processing of personal data at their disposal

and they are subject to regular controls in accordance with the legal regulations -

Personal Data Law

I, the user of this website, hereby agree that:

(i) In order to promote, support and realize our relations, the Company has

the right to process Personal Data.

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(ii) The Company will not disclose such Personal Data to any third party, unless

related to: (1) a company/companies to which the Company has partly or fully

assigned the realization of the processing of such data in accordance with the law,

(2) such communication or disclosure which may be required by law or by a court

decision and (3) where I am a Client of the Company according to the Privacy

Policy (below) which also applies to me.

The Company will apply the above to existing Clients and to applicants for any

kind of service with no relation to the fact that the application may be accepted

or not.

Set of information required for a Trading Account

If you decide to apply and become our Client, we will need certain information, in

order to open a trading account.

We can collect personal identification information from users in various ways, in

connection with the activities, services, features, or resources available on the

site.

We may collect Your Information directly from you (in your completed Account

Opening Application Form or other way) or from other persons including, for

example, credit reference agencies, fraud prevention agencies, banks,

other financial institutions, third authentication service providers and the

providers of public registers. This information includes, but is not limited to

personal details such as name, address, date of birth, contact details, payment

details, including credit card, debit card and bank account details, and other

necessary financial information.

We can also collect identity information for non-personal users whenever they

visit the site. Non-personal identification information may include the browser

name of the Internet, the type of computer, and technical information about the

connection used by the user when visiting the site, such as the operating system

and the internet service provider and related information.

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We may also require for further information to help us improve our Services to

you under our relevant Client Agreement. As well we may request any kind of

information needed to comply with Applicable Regulations.

How we treat Client Information

From the moment you will be our Client, we will manage, process, use, store and

handle Your Personal Information (in case you are a natural person) in connection

with the furthering of the Agreement between us, in accordance to the

Processing of Personal Data (Protection of the Individual) Law of 2001, as

amended or replaced form time to time.

Personal data can be stored and processed for statistical and marketing purposes

and for improve services in accordance with the General Terms. Users with use of

the Website gives consent to the use of this data by the Company.

We will use your data to provide the services to prevent and discover fraud,

money laundering and other dishonest activities, to enforce regulatory controls

and fulfill our obligations with respect to the appropriate regulatory authority and

to develop and improve our services in relation to you and other clients.

By entering a Client Agreement with us, you consent to the transfer of Your

Personal Information outside the European Economic Area, according to the

provisions of Processing of Personal Data (Protection of the Individual) Law of

2001.

Contacting the Client

If you use our services, we can occasionally use the information you provided in

the application for you we provide information by mail, email, message, MMS or

other form of electronic correspondence for products and services that would

interest you or conduct market research.

As well we may contact you from time to time directly by email, telephone, fax or

post in order to manage the terms of our Client Agreement between us.

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Client Information’s disclosure

We can disclose your personal information to our a legal successor, such as a

company to which we will join. In case of change of activity, merger or our

purchase by or with another company, or selling all or part of our funds, your

personal information can be found among the transferred assets. You will be

notified by email or by notice on our website for any changes to the ownership or

control of your personal data.

Your personal information is kept private and confidentiality. The Company does

not store any data of clients' cards. We may transfer your personal information as

instructed or permitted by law (including without limitation, to comply with a

court order).

Modification of Client’s information

You, as our Client, may inform the Company at any time that your Information

has changed or if you wish to delate your information we have. All this, You can

do by emailing us at info@apptrader.com . We can change or delete Your

information in accordance with your instructions, but we will retain only your

information that we need for regulatory and legal purposes so that we can

provide the Services you have requested or for our business records.

Measures of safeguard

We understand the protection of data seriously and we take various precautions

to protect personal identification information. In addition, your information is

stored on a server where only selected persons and service providers can access.

Only authorized persons have access to this information. In order to prevent

unauthorized access and abuse of personal data, all necessary technical and

organizational measures will be taken to protect your data.

However, we usually store the information needed to provide the service you

requested through the Web site, while we need to provide the service, that is, for

the purpose of implementing the Agreement between us and in accordance with

the obligations arising from the applicable legal regulations.

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The Company will keep your information in a form that allows identification no

longer than required to meet the purpose for which it was collected. Accordingly,

the Company will determine a deadline that is appropriate for meeting the target,

and after the expiration of the deadline, the outdated and unused information

will be destroyed in the earliest reasonable time. According to the applicable legal

regulations, we keep a record containing the client's personal data, documents

for opening and closing an account, trading information, communications, and

the like.

We keep this data for 5 years after the termination of the Agreement between us.

The data transfer over the Internet or any wireless network cannot be completely

secure. As a consequence, although we implement commercially reasonable

safeguards for data protection and we associate with the companies that do the

same, we can not guarantee the protection of any information transmitted on or

from our website and we are not responsible for the actions to any third party

who receives such information.

Questions

If you have questions about the Company's General Conditions or Practices or

Complaints, or if you have any questions about our website, please contact us at

info@apptrader.com.

Update of this Policy

The Company has the right to update this Policy at any time. We pay attention to

users frequently checking this page for any changes to be informed about the way

we provide protection of the personal information we collect. The user accepts

and agrees that it is his / her responsibility to periodically check the privacy policy

and be aware of the changes.

APPTRADER 10

Governing Law

Use of this site shall be governed by Laws of Saint Vincent and the Grenadines.

By using this site and any pages linked thereto, the user agrees with the

provisions of the personal privacy of the site. If you do not agree with the

policy, do not use our site. Your continued use of the site, following changes to

this policy, will be considered acceptance of the given changes.

RISK DISCLOSURE POLICY

Introduction

We advise the Clients and the prospective Clients to read carefully the risk disclosures

and warnings contained in this document, before applying to the Company for a trading

account and before they commence any trading.

Note that the contents of this document don’t explain or disclose all significant aspects

and risks involved when dealing in CFDs. According to the Law, this notice is designed

to explain in general terms the nature of the risks involved when dealing in CFDs on a

fair and non-misleading basis. Therefore, if the Client chooses to enter in a business

relationship with the Company, is important that (s)he fully understands the risks

involved before commencing trading and have adequate financial resources to bear

such risks.

Risks involving Third Parties

It is understood that the Company will promptly place any Client money it

receives into one or more segregated account(s) (denoted as ‘clients’ accounts’)

with reliable financial institutions (within or outside Saint Vincent and the

Grenadines) such as a credit institution or a bank in a third country. Although the

Company shall exercise due skill, care and diligence in the selection of the

financial institution according to Applicable Regulations, it is understood that

there are circumstances beyond the control of the Company and hence the

Company does not accept any liability or responsibility for any resulting losses to

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the Client as a result of the insolvency or any other analogous proceedings or

failure of the financial institution where Client money will be held.

The Client is warned that, in some cases, The Company may hold Client money

in a Client account, that is segregated from other the Company’s funds in

accordance with current regulations, but this may not afford complete protection.

The Company may transfer money received from the Client to a third party (e.g.

an intermediate broker, a bank, a market, a settlement agent, a clearing house,

an OTC counterparty located outside Saint Vincent and the Grenadines or to the

Liquidity Provider/Market Maker) to hold or control in order to facilitate the

Client’s transactions or to effect a Transaction through or with that party or to

satisfy the Client’s obligation to provide collateral (e.g. initial margin requirement)

in respect of a Transaction. The Company has no responsibility for the

insolvency, acts or omissions of any such third party to whom it will transfer

money received from the Client.

The financial institutions where Client money will be held may be within or

outside Saint Vincent and the Grenadines. It is understood that the legal and

regulatory regime applying to any such financial institution outside Saint Vincent

and the Grenadines will be different from that of Saint Vincent and the

Grenadines. Hence, in the event of the insolvency or any other equivalent failure

or proceeding of that person, the Client’s money may be treated differently from

the treatment which would apply if the money was held in a Segregated Account

in Saint Vincent and the Grenadines.

The financial institutions to which the Company will pass Client money may hold

it in an omnibus account. It is expressly stated to the Client that in the event of

the third party’s insolvency or other relevant event, in relation to that financial

institution, the Company may only have an unsecured claim against the financial

institution on behalf of the Client. It is also expressly stated to the Client that

there is a risk that the money received by the Company from the third party may

be insufficient in satisfying the Client’s claim in relation to their said account. The

Company does not and cannot bear any liability and/or responsibility for any

losses that may be the result of the above.

A Third Party (i.e. Bank or Broker) through whom the Company deals with could

have interests’ contrary to the Client’s Interests.

The Company may deposit Client money with a depository who may have a

security interest, lien or right of set-off in relation to that money.

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Insolvency

The Company’s insolvency or default, may lead to Client Open positions being closed

out without the Client’s consent and as a result the Client may suffer losses.

Taxes and charges

The Client is warned of the following:

(a) Fees maybe applied for the Provision of Services by the Company to the Client.

The Client should obtain details of all commissions, charges and fees for which

(s)he may be liable before accepting the Services from the Company. It is the

sole Client’s responsibility to check for any changes in the charges.

(b) The Client should ensure that he understands all the fees which may not be

expressed in monetary amounts like percentages, formulas, spreads or others.

The Company may apply changes to these its charges at any time.

(c) The Agreement or the transactions undertaken under the Agreement may be or

may become subject to tax and/or any other stamp duty in certain jurisdictions

and the Company does not warrant that no such tax and/or any other stamp duty

will be payable as such. The Company does not offer tax advice.

(d) The Client is the sole responsible for any taxes and/or any other duty which may

arise from his trades. It is noted that taxes are subject to change without notice.

(e) The Company’s prices may be different from prices reported elsewhere. The

prices displayed on the Company’s Trading Platform reflect the last known

available price the moment prior to placing any Order, however, the actual

execution price of the Order may differ, in accordance with the Company’s Best

Interest and Order Execution Policy and Client Agreement. As such, the price

that the Client receives when he opens or closes a position may not directly

correspond to real time market levels at the point in time at which the sale of the

CFD occurs.

Technical and Operational Risks

The Client is warned of the following technical risks, in addition to the ones stated in the

Agreement:

If the Client undertakes transactions on an electronic system, he will be exposed

to risks associated with the system including the failure of hardware and software

(Internet / Servers). The result of any system failure may be that his order is

APPTRADER 13

either not executed according to his instructions or it is not executed at all. The

Company does not accept any liability in the case of such a failure not owed to

the Company’s gross negligence or willful default. The Company strives on a

best effort basis to provide the Client with a secure and smooth online

experience however the Client acknowledges the risk that should third parties

(hackers) launch a coordinated attack against Company systems that there may

be a disruption of services that may result in Client losses. The Company does

not accept any liability resulting from such attacks to the extent that the Company

has taken all reasonable measures on a best effort basis to fend off such

malicious actions.

The Client shall be responsible for the risks of financial losses caused by failure,

malfunction, interruption, disconnection or malicious actions of information,

communication, electricity, electronic or other systems.

The Company has no responsibility if unauthorized third persons gain access to

Client information, including electronic addresses, electronic communication and

personal data, access data when this is due to the Client’s negligence or when

the above are transmitted between the Company and the Client or any other

party, using the internet or other network communication facilities, telephone, or

any other electronic means or post.

The Client accepts that the unencrypted information transmitted by e-mail is not

protected from any kind of unauthorized access.

The Client may have some difficulties to be connected over the phone or the

Company’s system(s), especially in volatile Market (for example, when key

macroeconomic indicators are released).

The Client acknowledges that the internet may be subject to events which may

affect his access to the Company’s Website and/or the Company’s trading

Platform(s)/system(s), including but not limited to interruptions or transmission

blackouts, software and hardware failure, internet disconnection, public electricity

network failures or hacker attacks. The Company is not responsible for any

damages or losses resulting from such events which are beyond its control or for

any other losses, costs, liabilities, or expenses (including, without limitation, loss

of profit) which may result from the Client’s inability to access the Company’s

Website and/or Trading System or delay or failure in sending orders or

Transactions, not owed to the Company’s gross negligence or willful default.

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In relation with the use of any kind of computer equipment and voice/data

communication networks, the Client carries the below risks on top of others not

mentioned risks for which the Company has no liability of any resulting loss:

a.) Damage or destruction (physical) of the communication channels used to

link the Client and provider (communication operator), and the trading or

information server of the Client.

b.) Any power cut of the equipment on the Client side or of the Client’s

provider or operator, including voice communication.

c.) Outage (very low quality) of communication via the channels used by the

Client, or the channels used by the provider, or communication operator

(including voice communication) that are used by the Client.

d.) Malfunction or non-operability of the Platform, which also includes the

Client Terminal.

e.) When connecting by telephone (land or cell phone lines) voice

communication, the Client carries the risk of issues in dialing, when trying

to reach an employee of the broker service department of the Company

due to communication quality problems and communication channel

loads.

f.) The use of communication channels, hardware and software, includes the

risk of non-reception of a message (including text messages) by the Client

from the Company.

g.) Trading over the phone might be impossible because of an overload in the

connection.

h.) Wrong or inconsistent settings of the Client Terminal.

i.) Untimely update of the Client Terminal.

The Company accepts no responsibility or liability in case of financial losses the Client

may suffer due to the above-mentioned cases. Only the Client shall be responsible for

all the related losses he may suffer except for Company’s gross negligence or willful

default.

The Trading Platform

The Client is warned that while trading in an electronic platform he assumes risk of

financial loss which may be a consequence of amongst other things:

The Company’s or Client’s hardware or software malfunction, wrong use or

failure.

Inappropriate work of Client’s equipment.

Failure of Client’s devices, software and poor quality of connection.

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Untimely updates of Client’s Terminal.

Wrong setting of Client’s Terminal.

The Client acknowledges and accepts that the only reliable source of information/data is

the one which is presented on the Company’s live server, and that this service is not a

reliable source of information/data because the connection between the Client’s

Terminal and the Company’s Server may be disrupted at some point, through no fault of

our own, resulting in some of the information, data or quotes not reaching the Client’s

Terminal or not being made available to the Client.

The Client acknowledges that when an Order is closed or is being executed, it may not

be cancelled or modified.

Client orders/instructions may be executed one at a time while being in the queue.

Multiple client orders/instructions from the same Client trading account at the same time

may not be executed.

The Client may not receive the result of the execution of a previously sent

instruction/order and nevertheless takes the decision to repeat the instruction/order. In a

case like this the Client is accepting the risk of making two transactions instead of one.

The Client acknowledges that if a Pending Order has already been executed but the

Client sends an instruction to modify its level, the only instruction, which will be

executed, is the instruction to modify Stop Loss and/or Take Profit levels on the position

opened when the Pending Order triggered.

Force Majeure

The Company may not be in condition to perform the execution of Client Orders or fulfill

its obligations under the Client Agreement or delay in performing its obligations in case

of a Force Majeure Event. As a result, the Client may suffer financial losses. According

to the Client Agreement the Company will not be liable or have any responsibility for any

type of loss or damage emerging, directly or indirectly, due to a Force Majeure event.

Unusual Market Conditions

Abnormal Market Conditions include but not limited to times of rapid price fluctuations of

the price, rises or falls in one trading session to such an extent that, under the rules of

the relevant exchange, trading is suspended or restricted, or there is lack of liquidity, or

this may occur at the opening of trading sessions.

The Client acknowledges that under Abnormal Market Conditions the period during

which the Orders are executed may be extended or it may be impossible for Orders to

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be executed at declared prices or may not be executed at all. In these cases, Stop Limit

and Stop Loss Orders cannot guarantee the limit of loss.

Foreign Currency

When a Financial Instrument is traded in a currency other than the currency of the

Client’s country of residence and/or Trading Account, any changes in the exchange

rates may have a negative effect on its value, price and performance and may lead to

losses for the Client.

A Financial Instrument with a currency as the underlying asset, the prospect of profit or

loss from transactions on foreign markets is also affected by exchange rate fluctuations.

The Client’s attention is expressly drawn to currencies traded so irregularly or

infrequently that it cannot be certain that a price will be quoted always or that it may be

difficult to effect transactions at a price which may be quoted owing to the absence of a

counter party.

The Client and the Company

The Company bears no responsibility and the Client shall accept the risk of any damage

or that arise because of delayed or non-received communication sent by the Company

to the Client.

The Client acknowledges that unencrypted information transmitted by e-mail is not

protected from any unauthorized access. The Company bears not responsibility for any

damage or loss that arises because of unencrypted information sent to the Client by the

Company that has been accessed through unauthorized means.

The Company bears no responsibility if unauthorized third persons have access to

information, including electronic addresses, electronic communication and personal

data, access data when the above are transmitted between the Company and the Client

or when using the internet or other network communication facilities, telephone, or any

other electronic means.

The Client is the sole responsible for any non-received or unread internal messages

sent to the Customer via the internal systems or trading platform(s). The Company

cannot be held liable for those messages that the Customer fails to receive, open or

understand due to the failure of the email system and/or communication channel or

corruption of the intended message.

Risks particularly associated with transactions in Derivative Financial

Instruments such as CFDs.

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The Client must not purchase a Derivative Financial Instrument (i.e. option, future,

forward, swap, Contract for Difference) unless he is willing to undertake the risks of

losing partial or all the money which he has invested, and any additional commissions

and other expenses incurred.

All Clients wishing to invest in Contracts for Differences (CFDs) should carefully read

this part. However, it is noted that the information in this document cannot and does not

disclose or explain all the risks and other significant aspects involved in dealing in

CFDs. It is emphasized that for many members of the public dealings in CFDs will not

be appropriate. So, the Client should not engage in any dealings directly or indirectly in

CFDs unless he knows and understands the features risks involved in them and that he

may lose partial or all his money and also be imposed of extra charges.

Trading CFDs can put Client’s capital at risk as CFDs are categorized as high risk

complex Financial Instruments and Clients may lose the amount invested. Trading

CFDs may not be suitable for all investors.

Set out below is an outline of the major risks and other significant aspects of CFDs:

Trading in CFDs is VERY SPECULATIVE AND HIGHLY RISKY and is not suitable for

all members of the wide public but only for those investors who:

I. understand and are willing to assume the legal, financial and other

risks involved.

II. take in consideration their personal financial circumstances, resources,

obligations, life style and they can afford the loss of all their

investment.

III. have the awareness to understand CFDs trading and the underlying

assets and markets.

The Company will not provide the Client with any advice relating to CFDs trading, the

Underlying Assets and Markets or give investment recommendations. If the Client does

not understand the risks involved he should ask for consultation from an external

financial advisor. If, after having consulted and expert, the Client still does not

understand the risks involved in CFD’s trading, then he should not trade at all.

CFDs are derivative financial instruments, where their price is derived from the price of

the underlying asset in which the CFDs refer to (for example currency pair, stocks,

metals, indices etc.). Derivative financial instruments and related underlying markets

can be highly volatile. The prices of CFDs and the underlying asset may fluctuate

rapidly and over wide ranges and may reflect unforeseeable events or changes in

conditions, none of which can be controlled by the Client or the Company. Under certain

market conditions it may be impossible for a Client’s order to be executed at declared

price leading to losses or be executed at all. The prices of CFDs will be influenced by,

APPTRADER 18

amongst other things, changing supply and demand relationships, governmental,

agricultural, commercial and trade programs and policies, national and international

political and economic events and the prevailing psychological characteristics of the

relevant underlying market place. It is important therefore that the Client understands

the risks associated with trading in the relevant underlying asset/market because

fluctuations in the price of the underlying asset/market will affect the profitability of

his/her trade.

Information of the previous performance of a CFD’s does not guarantee its current

and/or future performance. The use of historical data does not give us any certainty

about the future performance of the CFDs involved.

Volatile markets

Some derivative financial instruments can be highly volatile or unpredictable. The price

of derivative financial instruments is derived by the price of the underlying asset and

may fluctuate rapidly and over wide ranges and may reflect unforeseeable events or

changes in conditions, none of which can be controlled by the Client or the Company.

Under certain market conditions it may be impossible for a Client’s order to be executed

at declared price leading to losses or be executed at all. The prices of CFDs are

influenced by, amongst other things, changing supply and demand relationships,

governmental, agricultural, commercial and trade programs and policies, national and

international political and economic events and the prevailing psychological

characteristics of the relevant underlying market place.

During periods of market volatility, it may be difficult or impossible for you to liquidate an

existing position, to assess the value of open positions, to determine a fair price or to

assess the exposure to risk. These are among the reasons why Transactions in CFDs

involve increased risks.

Liquidity risk

Liquidity risk can affect your ability to trade. Some of the CFDs underlying instruments

may not become immediately liquid because of a reduced demand for the underlying

instrument and Client may not be able to obtain the information on the value of these or

the extent of the associated risks.

Leverage

CFD trading enables the client to trade the markets by paying only a small fraction of

the total trade value. This is known as “leverage” or “gearing” which is a feature of a

derivative financial instruments, and stems from the margining system applicable to

such trades, according to which, the amount of initial margin funds may be

comparatively small or modest in relation to the overall contract value.

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Hence a relatively small market movement can have a disproportionately larger impact

on the Client’s trade and/or deposited funds. This may work for or against the Client. If

the underlying market movement is in the Client’s favor, the Client may achieve a good

profit, but an equally adverse market movement can not only result in the loss of the

Client’s entire capital, but also expose the Client to a large additional loss. Hence if the

market moves against the Client’s position and/or margin requirements are increased,

the Client may be called upon to deposit additional funds on short notice to maintain

his/her position. Failing to comply with a request for a deposit of additional funds, may

result in closure of his/her position(s) by the Company on his behalf and (s)he will be

liable for any resulting loss or deficit.

The Margin

Before the Client opens a CFD trade with the Company (s)he is required to deposit

funds as initial margin. Please note that the initial margin requirements differ per

financial instruments. Moreover, to keep a transaction/position open the Client must

ensure that the balance of the trading account exceeds the maintenance margin.

The Client acknowledges and accepts that, regardless of any information which may be

offered by the Company, the value of any investment in financial instruments may

fluctuate downwards or upwards and it is even probable that the investment may

become of no value. This is owed to the margining system applicable to such trades. A

small price movement in the Client’s favor may result in high return on the initial margin

placed for a trade, but equally a small price movement against the Client may result in

loss of the entire initial margin as well as require the provision of substantial additional

margin, at short notice, to maintain an open position/trade. If the Client does not do this,

the Company will be entitled to close one or more of his/her trades and the Client will be

responsible for any losses incurred.

Strategies to reduce the risk

The Company makes available certain Orders (e.g. "stop-loss" orders, where permitted

under local law, or "stop-limit" Orders), which can limit losses to certain amounts. Such

Orders may not be adequate given that markets conditions make it impossible to

execute such Orders, e.g. due to lack of liquidity in the market. We aim to deal with

such Orders fairly and promptly, but the time taken to fill the Order and level at which

the Order is filled depends upon the underlying market. In fast-moving markets, a price

for the level of your Order might not be available, or the market might move quickly and

significantly away from the stop level before we fill it.

Strategies using combinations of positions, such as "spread" and "straddle"' positions

may be as risky as taking simple "long" or "short" positions therefore Stop Limit and

Stop Loss Orders cannot guarantee the limit of loss.

APPTRADER 20

As well we remind that the use of Expert Advisor tools cannot guarantee the limit of

losses.

Contracts for Differences

A CFD is an agreement to buy or sell a contract which reflects the performance for

example of precious metals, futures or shares. The profit or loss is determined by the

difference between the price the CFD is bought at and the price is sold at and vice

versa. CFDs are traded on a margin. The CFDs available for trading with the Company

are non-deliverable spot transactions giving an opportunity to make profit on changes in

the Underlying Asset.

CFDs available for trading with the Company are non-deliverable/transactions giving an

opportunity to make profit on changes in the Underlying Asset (stocks, currencies,

commodities, precious metals and any other asset according to the Company’s

discretion from time to time). If the Underlying Asset movement is in the Client’s favor,

the Client may achieve a good profit, but as well a small adverse market movement can

not only quickly result in the loss of the Clients’ entire deposit but also any additional

commissions and other expenses may be incurred. In conclusion the Client must not

enter CFDs unless he is willing to undertake the risks of losing the entire invested funds

and additional commissions or expenses.

Investing in CFDs carries risks and the Client should be aware of these risks.

Transactions in CFDs may also have a contingent liability and the Client should be

aware of the implications of this as indicated in the section below the next one.

Trading off-exchange transactions

CFDs offered by the Company are off-exchange transactions (i.e. over-the-counter).

The trading conditions are set by us (in line with the trading conditions received by our

liquidity providers), subject to obligations we must provide best execution, to act

reasonably and in accordance with our Client Agreement and with Best Interest and

Order Execution Policy. Each CFD trade that the Client opens through our Trading

Platform results in the entering of an Order with the Company; such Orders can only be

closed with the Company and are not transferable to any other person.

While some off-exchange markets are highly liquid, transactions in off-exchange or non-

transferable derivatives may involve greater risk than investing in on-exchange

derivatives because there is no exchange market on which to close out an Open

Position. It may be impossible to liquidate an existing position, to assess the value of

the position arising from an off-exchange transaction or to assess the exposure to risk.

Prices need not be quoted, and, even where they are, they will be established by

dealers in these instruments and consequently it may be difficult to establish what a fair

price is.

APPTRADER 21

The Company is using an Online Trading System for transactions in CFDs which does

not fall into the definition of a Regulated Market or Multilateral Trading Facility and as

such does not have the same protection.

Contingent Liability Investment Transactions

Contingent liabilities are potential obligations that may be assumed by the Client

depending on the outcome of an event that was beyond any person’s control and/or

expectations. For example, in case whereby due to extreme volatility of the underlying

instrument the Client has sustained losses that exceed his balance with the Company

(i.e. he has generated a negative balance with the Company), the Client may be then

called to pay an amount equal to these losses.

Some financial instruments have a contingent liability and the Client should be aware of

the implications of this, in particular the margining requirements of the Company.

Contingent liability investment transactions require the Client to make a series of

payments against the purchase price, instead of paying the whole purchase price

immediately. The Margin requirement will depend on the underlying asset of the

Financial Instrument, the chosen level of leverage and the value of the position. Margin

requirements can be fixed or calculated from current price of the underlying instrument

and it can be found on the website of the Company.

If the Client trades in futures or Contracts for Differences or sell options, he may sustain

a total loss of the funds he has deposited to open and maintain a position. If the market

moves against the Client, he may be requested to pay substantial additional funds at

short notice to maintain the position. If the Client does not do so within the time

required, his position may be closed with a loss and he will be responsible for it.

In addition to the amount paid when the Client entered the contract, even if a

transaction is not margined, it may still require making further payments in certain

circumstances.

Collateral

Where transactions require a transfer or the depositing of collateral as security with a

counterparty or a central counterparty, these counterparties may treat such collateral

differently according to the type of transaction and where it is traded. There could be

significant differences in the treatment of your collateral depending on whether the

trading is on a regulated market, with the rules of that market applying, is off-exchange

or such transaction is cleared through a central counterparty. Transferred collateral may

lose its identity as your property once transferred to the broker or counterparty. Even if

your dealings should ultimately prove profitable, you may have to accept payment in

cash and not get back the same assets which was paid on your behalf.

APPTRADER 22

Overnight Premium

Overnight Premium also known as an overnight fee, it's an interest payment that may

apply if you hold a position overnight. It particularly applies to contracts for difference

(CFDs). The interest is based on the value of the contract and is calculated daily. If you

hold a short position you earn this interest but if you hold a long position you pay this

charge.

Details of daily financing fees applied are available in the Company’s website.

Slippage

Slippage is the difference between the order price (i.e. the expected traded price) and

the actual execution price. This may occur because the specific underlying market has

become unusually volatile. For instance, the underlying market may have stopped

trading at a point above your Stop Loss order price and after a period, may

recommence trading at a price below your Stop Loss order price.

Various factors can lead to slippage (for example, economic events or market

announcements) and can occur both when the underlying market is open and when it is

closed.

Restriction of trading

Market conditions (e.g. illiquidity) and/or the operation of the rules of certain markets

(e.g. the suspension of trading in any contract or contract month because of price limits,

government intervention or reasons beyond the counterparty’s control) may increase

the risk of loss by making it difficult or impossible to effect transactions or liquidate/offset

positions.

Under certain trading conditions it may be difficult or impossible to liquidate a position.

This may occur, for example, at times of rapid price movement if the price rises or falls

in one trading session to such an extent that under the rules of the relevant exchange

trading is suspended or restricted. Placing a Stop Loss will not necessarily limit the

Client’s losses to the intended amounts, because market conditions may make it

impossible to execute such an Order at the stipulated price.

No Delivery or rights to the underlying assets/instruments

The Client acknowledges that (s)he has no rights or obligations in respect of the

Underlying Assets or Instruments relating to the CFDs (s)he is trading. The Client is not

entitled to ownership of the underlying assets or instruments and there is no delivery of

the underlying asset or instrument.

APPTRADER 23

Recommendations

Where the Company provides general market recommendations, such

recommendations do not constitute a personal recommendation or investment advice

and have not considered any of the Client’s personal circumstances or his/her

investment objectives, nor is it an offer to trade, or the solicitation of an offer to trade, in

any CFDs. Hence each decision by Client to trade in CFDs and each decision as to

whether a transaction is appropriate or proper for the Client, is an independent decision

made by the Client. In asking the Company to enter into any Transaction, the Client

represents that (s)he has been solely responsible for making his/her own independent

appraisal and that (s)he has sufficient knowledge, market sophistication, professional

advice and experience to make his/her own evaluation of the merits and risks of any

Transaction.

The Company is not acting as an advisor or serving as a fiduciary to the Client. The

Client acknowledges and agrees that the Company has no fiduciary duty to the Client

and no liability in connection with and is not responsible for any liabilities, claims,

damages, indemnifications, costs and/or expenses, including attorneys’ fees and/or any

legal proceedings, incurred in connection with the Client following the Company’s

general trading recommendations or by taking or not taking any action based upon any

general recommendation or information provided by the Company.

Apart from general market recommendations, the Company may, from time to time and

at its discretion, provide the Client with information, market commentary or other

information via newsletters (which are posted on the Company’s website(s) or

distributed to its clients or potential clients with mass emails) or posted on the

Company’s trading platform(s) or otherwise. This is not a service. Where it does so:

the Company will not be responsible for such information as they

are solely based on the judgement of the Company’s personnel and

should be considered as such;

the information provided are based upon sources believed to be

reliable, but the Company gives no representation, warranty or

guarantee as to the accuracy, correctness or completeness of such

information or as to the tax or legal consequences of any related

Transaction;

this information is provided solely to enable the Client to make

his/her own investment decisions and does not amount to

investment advice or unsolicited financial promotions to the Client.

The Client acknowledges that it enters into any such transactions or

trades relying on his/her own judgement;

APPTRADER 24

this information is general only and may or may not be consistent

with the market positions or intentions of the Company and/or its

affiliates.;

if the document contains a restriction on the person or category of

persons for whom that document is intended or to whom it is

distributed, the Client agrees that he will not pass it on to any such

person or category of persons;

the Client accepts that prior to dispatch, the Company may have

acted upon it itself to make use of the information on which it is

based. The Company does not make representations as to the time

of receipt by the Client and cannot guarantee that he will receive

such information at the same time as other clients.

The Client understand that the Company can change and withdrawn at any time without

notice, all market commentary, news or other information provided.

No Guarantees of Profit

The Company does not provide guarantees of profit or of avoiding losses when trading

in Financial Instruments. The Company cannot guarantee the future performance of the

Client’s Τrading Αccount, promise any specific level of performance or promise that

Client’s investment decisions, strategies, will be successful/profitable. The Customer

has not received such guarantees from the Company or from any of its representatives.

The Customer is aware of the risks related to Financial Instruments trading and is

financially able to afford such risks and endure any losses incurred. The Client

acknowledges and accepts that there may be other additional risks apart from those

mentioned above.