Our legal and regulatory
framework

Rocktrading Ltd (the "Company") aims to actively prohibit, detect and pursue the prevention of money laundering and terrorist financing activities. The Company is also committed to complying fully with all applicable laws, rules and regulations relating thereto, without compromising any of the activities mentioned above.

The Company’s management is committed to compliance with Anti-Money Laundering ("AML") and Counter-Terrorist Financing ("CFT") requirements in accordance with applicable laws, and places extremely high importance on the detection and disclosure of any money laundering scheme and/or terrorist financing activities.

Rocktrading Ltd also requires its officers, employees, introducing brokers and affiliated companies to adhere to these standards in order to prevent the use of the Company’s products and services for money laundering and terrorist financing activities.

The purpose of the "AML, CFT and KYC Policy" (the "Policy") is to provide guidance on the Anti-Money Laundering ("AML"), Counter-Terrorist Financing ("CFT") and Know Your Customer ("KYC") measures followed by the Company to achieve full compliance with applicable AML and CTF legislation.

This Policy applies to all Company officers, affiliated companies, and the products and services offered by the Company. Any employee who fails to comply with these policies and procedures will be subject to severe disciplinary action.

The Company is required to comply with the provisions of applicable laws concerning the prevention of Money Laundering and Terrorist Financing. The primary objective of these laws is to define and criminalize the laundering of proceeds generated from all serious crimes, with the aim of depriving criminals of the proceeds of their crimes.

In accordance with AML and CTF laws, the Company is required to establish policies and procedures to prevent money laundering and terrorist financing activities.

4.1 – Money Laundering

Money laundering is the process of creating the appearance that large amounts of money obtained from serious crimes, such as drug trafficking or terrorist activity, originated from a legitimate source.

There are three stages involved in the money laundering process: placement, layering and integration.

4.1.1 – Placement

Placement refers to the act of introducing "dirty money" (money obtained through illegitimate and criminal means).

4.1.2 – Layering

Layering is the act of concealing the source of such money through a series of complex transactions and accounting maneuvers.

4.1.3 – Integration

Integration refers to the act of acquiring or returning such money through apparently legitimate means.

4.2 – Terrorist Financing

Terrorist financing is the process through which funds are provided to finance or financially support individual terrorists or terrorist groups.

A terrorist or terrorist group is one whose purpose or activity is to facilitate or carry out any terrorist action and may involve individuals or groups.

4.3 – AML / CTF

The term AML/CTF refers to "Anti-Money Laundering and Counter-Terrorist Financing" or "Anti-Money Laundering and Countering the Financing of Terrorism".

4.3.1 – Anti-Money Laundering

Anti-Money Laundering ("AML") refers to a set of procedures, laws or regulations designed to prevent the practice of generating income through illegal actions.

4.3.2 – Counter-Terrorist Financing

Counter-Terrorist Financing ("CTF") refers to a set of procedures, laws or regulations designed to prevent the financing of or provision of financial support to individual terrorists or terrorist groups.

4.4 – Financial Action Task Force (FATF)

The Financial Action Task Force on Money Laundering ("FATF"), also known by its French name, Groupe d’action financière (GAFI), is an intergovernmental organization established in July 1989 by the Group of Seven (G-7) summit in Paris, initially to examine and develop measures to combat money laundering.

In October 2001, FATF expanded its mandate to incorporate efforts to combat terrorist financing in addition to money laundering.

The objectives of FATF are to establish standards and promote the effective implementation of legal, regulatory and operational measures to combat money laundering, terrorist financing and other related threats to the integrity of the international financial system.

Beginning with its own members, FATF monitors countries’ progress in implementing the FATF Recommendations; reviews money laundering and terrorist financing techniques and countermeasures; and promotes the adoption and implementation of the FATF Recommendations worldwide.

The Working Group was responsible for examining money laundering techniques and trends, reviewing actions already taken at national or international level, and establishing the measures that still needed to be taken to combat money laundering.

In April 1990, less than one year after its creation, FATF issued a report containing a set of Forty Recommendations, intended to provide a comprehensive action plan necessary to combat money laundering.

In 2001, the development of standards to combat terrorist financing was added to FATF’s mission.

In October 2004, FATF published Nine Special Recommendations, further strengthening the agreed international standards for combating money laundering and terrorist financing: the 40 + 9 Recommendations.

In February 2012, FATF completed a comprehensive review of its standards and published the revised FATF Recommendations. This review was intended to strengthen global safeguards and further protect the integrity of the financial system by providing governments with stronger tools to take action against financial crime.

These standards were expanded to address new threats, such as the financing of the proliferation of weapons of mass destruction. The new standards also impose higher levels of transparency and stricter regulations to prevent corruption.

The nine Special Recommendations on terrorist financing have been fully integrated with the anti-money laundering measures. This has resulted in a stronger and clearer set of standards.

The provisions of the Laws adopted by the Company introduce procedures and processes that ensure compliance with applicable Laws relating to Money Laundering and Terrorist Financing activities.

5.1 – Customer Categorization and Identification Procedures

The Company has adopted all requirements of applicable laws in relation to customer categorization and identification and customer due diligence procedures, as explained below.

5.1.1 – Customer Categorization

Customers are classified according to their risk profile into three main categories:

a – Low-Risk Customers

The following types of customers are considered lower risk. The Company will collect sufficient information to establish whether the customer qualifies to be classified as a lower-risk customer:

i – Credit or financial institutions located in another country that impose requirements higher than or equivalent to those established by the Company’s regulators.

ii – Listed companies whose securities are admitted to trading on a regulated market in other countries and which are subject to disclosure requirements compatible with Community legislation.

b – Normal-Risk Customers

All customers who are neither High-Risk nor Low-Risk Customers will be considered Normal-Risk Customers.

c – High-Risk Customers

Customers meeting the following criteria are classified as high risk:

i – Non-face-to-face customers.

ii – Customer accounts held in the name of a third party.

iii – Accounts of Politically Exposed Persons ("PEPs").

iv – Betting / online gambling activities.

v – Customers from countries that inadequately apply FATF Recommendations.

vi – Customers whose nature presents a higher risk of money laundering and terrorist financing.

vii – Any other Customer that the Company itself determines should be classified as such.

5.1.2 – Customer Identification (Due Diligence)

a – Due Diligence Conditions

Customer Identification and Due Diligence procedures apply under the following conditions:

i – Establishment of a business relationship.

ii – There is a suspicion of money laundering or terrorist financing, regardless of the transaction amount.

iii – There are doubts regarding the adequacy of previously obtained customer identification data.

iv – A customer’s failure or refusal, without proper justification, to provide the data and information required to verify their identity and establish their economic profile.

b – Timing of Due Diligence

i – Customer identification and due diligence must take place before establishing a business relationship or carrying out a transaction.

ii – Verification of the customer’s identity may be completed during the establishment of a business relationship if necessary to avoid interrupting the normal course of business and where there is a limited risk of money laundering or terrorist financing. In such circumstances, these procedures must be completed as soon as possible.

iii – Reviews of existing records must be performed regularly, ensuring that documents, data or information retained are kept up to date.

iv – A customer’s failure or refusal, without proper justification, to provide the data and information required to verify their identity and establish their economic profile.

v – When a customer account is opened, it must be closely monitored.

vi – Customer due diligence procedures will apply not only to all new customers, but also, at appropriate times, to existing customers on a risk-sensitive basis.

vii – At frequent intervals, the Company must compare the estimated account turnover with the actual turnover.

viii – Any significant deviation must be investigated, not only for possible action by the Company in relation to the particular account concerned, but also to assess the reliability of the person or entity that introduced the customer.

c – Due Diligence Procedures

The practice followed by the Company to comply with legal requirements concerning customer identification is based on a risk-based approach.

i – Standard Customer Due Diligence Procedure

Identification of the customer and verification of the customer’s identity based on information obtained from a reliable and independent source.

For legal persons, taking appropriate and risk-based measures to understand the customer’s ownership and control structure.

Obtaining information on the purpose and intended nature of the business relationship.

Continuously monitoring the business relationship, including scrutiny of transactions carried out throughout the relationship, to ensure that the transactions conducted are consistent with the data and information held by the Company in relation to the customer.

ii – Simplified Due Diligence Procedure

Simplified procedures may be applied to low-risk customers. These measures will be applied where there is no suspicion of money laundering, irrespective of any derogation, exemption or threshold, and not necessarily whenever a business relationship is established.

iii – Enhanced Customer Due Diligence Procedure

The Company must apply enhanced customer due diligence measures in situations that, by their nature, may present a high risk of money laundering or terrorist financing.

The Company will take specific and appropriate measures to mitigate the high risk by applying one or more of the following measures:

Ensuring that the customer’s identity is established through additional documents, data or information.

Applying additional measures to verify or certify the documents provided.

Ensuring that the first payment for transactions is made through an account opened in the customer’s name. Such account must be held with a credit institution operating in a country that imposes requirements higher than or equivalent to those established by the Company’s regulators.

d – Verification Procedure

The Company will follow the procedure below to verify the customer’s identity during the establishment of the business relationship:

i – The Company will ensure that the construction of the economic profile, suitability assessment and appropriateness assessment are carried out prior to establishing the business relationship.

ii – Customers have a grace period of fifteen (15) days to provide their identification documents to the Company. During this 15-day period, the Company must ensure the following:

The cumulative amount of funds to be deposited will not exceed USD 5,000.

Funds may originate only from a bank account or through other means linked to a bank account in the customer’s name.

Notification/reminder emails will be sent to customers requesting the customer identification documents.

The account will be closed where the verification procedure has not been completed after the grace period.

The Company will not retain any customer funds and accounts will not be frozen unless they are subject to a suspicion of money laundering.

e – Other Matters Related to Due Diligence

i – Politically Exposed Persons

Politically Exposed Persons ("PEPs") are persons who have been entrusted with prominent public functions in a foreign country, as well as persons who have a close relationship with politically exposed persons.

The Company must adopt the following additional due diligence measures to determine whether a prospective customer is a politically exposed person:

Special approval from Senior Management prior to establishing a business relationship with the customer.

Taking appropriate measures to establish the source of the customer’s assets and the source of funds related to the establishment of the business relationship or transaction.

Conducting enhanced and continuous monitoring of the business relationship.

ii – Anonymous or Numbered Accounts

The Company is prohibited from maintaining anonymous or numbered accounts. In addition, the Company must pay special attention to any money laundering or terrorist financing threat that may arise from products or transactions that favor anonymity. The Company will also take the necessary measures to prevent their use for money laundering or terrorist financing purposes.

iii – Reliance on Third Parties for Due Diligence

The Company is authorized to, and may, rely on third parties to fulfill customer due diligence requirements. However, in such cases, ultimate responsibility for compliance with those requirements will remain with the Company.

5.2 – Customer Account Opening Procedures and KYC Documentation

Before accepting new customers, the Company will require such customers to provide certain information and identification documents.

5.2.1 – Account Opening

a – Information Required for Account Opening

All prospective customers interested in opening an account with the Company are required to provide certain information, including:

i – Customer personal data.

ii – Construction of the customer’s economic profile.

iii – Customer suitability / appropriateness assessment.

Customer identification, including the construction of the economic profile and the suitability / appropriateness assessment, will be carried out before establishing the business relationship with the customer.

b – Account Opening Procedure

i – The customer completes the account opening forms by providing all required information.

ii – The responsible administrator collects all initial customer information and submits it directly to Senior Management and the Anti-Money Laundering Compliance Officer for examination, review and approval.

iii – Following approval, the administrator records all necessary information in the Company’s software systems and communicates it to the relevant departments.

5.2.2 – KYC Documentation

Before accepting new customers and allowing them to trade with the Company, the following documents must be obtained to verify the customers’ identities.

a – Individuals

i – Proof of Identity

A valid government-issued proof of identity (passport, national identity card, driving licence, etc.) must include the customer’s full name, date of birth, photograph and validity status (expiry date and/or issue date + validity period). It is also essential that the customer take a photograph showing them holding the identity document together with their face, also known as a selfie.

ii – Proof of Residence / Address

A recent proof of address in the person’s name (bank statement, utility bills, telephone bills, etc.) must include the customer’s full name, residential address and issue date (it must not be more than 6 months old).

b – Legal Persons

A different identification procedure is followed for legal persons (corporate customers) interested in opening an account with the Company.

i – Incorporation Documents

The form and name of corporate documents may vary depending on the country of incorporation and/or the legal form of the company. However, the required government-issued corporate documents must include the corporation’s name, date and place of incorporation, registered office address, directors and authorized signatories, ownership/shareholding structure (shareholders’ names and ownership percentages), and registered corporate activities.

These documents may include, among others, a certificate of incorporation or registration certificate, registered office certificate, certificate of directors and secretary, certificate of registered shareholders, memorandum and articles of association.

ii – Directors’ and Beneficial Owners’ Documents

Personal identification and KYC documents are required for directors of legal persons, and for ultimate beneficial owners of the legal person holding 10% or more beneficial ownership. These identification documents include proof of identity and proof of residence.

iii – Board Resolution

A board resolution of the legal person for the opening of the account and granting authority to the persons who will operate it.

5.3 – Record-Keeping Procedures

The Company must retain the information and documents listed below for use in any investigation or analysis of potential money laundering or terrorist financing by national authorities.

Retention of documents/data, other than original documents or certified true copies maintained in hard copy, may be carried out in other forms, such as electronic format, provided that the Company can retrieve the relevant documents/data without undue delay and present them at any time to the competent authorities upon request. A true translation will be attached where documents/data are in a language other than English.

a – The names and addresses of customers and copies or records of official identification documents (such as passports, identity cards or driving licences).

b – The name and address (or identification code) of counterparties.

c – Details of the account from which funds were paid.

d – The form and destination of payments made by the Company to the customer.

e – Business correspondence.

f – For customer due diligence, copies of supporting evidence must be retained for at least 5 years after the business relationship with the customer has ended.

g – For business relationships and transactions, supporting evidence and records must be retained for at least five years after the transactions have been carried out or after the end of the business relationship.

5.4 – Suspicious Transaction Reporting

A suspicious transaction is a transaction that is inconsistent with a customer’s known legitimate business or personal activities, or with the normal business of the specific account, or generally with the economic profile that the Company has established for the customer.

The Company ensures that it maintains adequate information at all times and knows enough about its customers’ activities to recognize in a timely manner when a transaction or series of transactions is unusual or suspicious.

5.4.1 – Examples of Suspicious Transactions

Examples of transactions/activities that could constitute suspicious transactions relating to money laundering and terrorist financing include, but are not limited to:

a – Transactions with no discernible purpose or that are unnecessarily complex.

b – Use of foreign corporate accounts, or groups of companies with complicated ownership structures, which cannot be justified based on the customer’s needs and economic profile.

c – A large volume of transactions and/or money deposited or credited to an account where the nature of the customer’s business activities does not appear to justify such activity.

d – There is no apparent justification for a customer to use the services of a particular financial organization.

e – Frequent transactions in the same financial instrument without an apparent reason and under conditions that appear unusual.

f – Frequent small purchases of a particular financial instrument by a customer who settles in cash, followed by the sale of the total number of financial instruments in a transaction settled in cash, or with the proceeds transferred, at the customer’s instructions, to an account other than their own.

g – Transactions that do not conform to prevailing market conditions, particularly in relation to the size and frequency of the order.

h – Settlement of any transaction, particularly a large transaction, in cash and/or through a third party who did not place the order.

i – Settlement of any transaction, particularly large transactions, in cash and/or settlement of the transaction by a third party other than the customer who placed the order.

j – Transfer of funds to and from countries or geographical areas that do not apply, or inadequately apply, FATF Recommendations on money laundering and terrorist financing.

k – Reluctance to provide complete personal information when establishing a business relationship, including information regarding the nature and purpose of business activities, expected account activity, previous relationships with financial organizations, names of officers and directors, or business address.

l – Providing minimal information that is difficult or costly for the Company to verify.

m – Providing unusual or suspicious identification documents that cannot be easily verified.

n – Frequent or large transactions by a customer with no record of past or present employment experience.

o – Introduction of a customer through a foreign financial organization, or a third party whose country/countries or geographical area(s) of origin do not apply, or inadequately apply, FATF Recommendations on money laundering and terrorist financing.

p – Use of an address linked to persons involved in cash transactions, particularly where the same address does not correspond to the declared occupation (e.g., student, unemployed, self-employed, etc.).

q – Shared address for persons involved in cash transactions, particularly where the address is also a business location and/or does not appear to correspond to the declared occupation (e.g., student, unemployed, self-employed, etc.).

r – The customer’s declared occupation is not consistent with the level or size of the transactions executed.

s – Use of general nominee documents in a manner that restricts the control exercised by the company’s board of directors.

5.4.2 – Suspicious Transaction Reporting Procedure

The procedure for reporting a suspicious customer transaction is as follows:

a – Reports from Company employees in different departments are assessed by the AML Compliance Officer.

b – If deemed necessary, the Compliance Officer will notify the relevant Money Laundering Authorities.

c – After the report is filed, the customer’s account(s), as well as any other connected accounts, are closely monitored by the Compliance Officer.

d – After the report is filed, the Company adheres to the instructions given by the relevant Money Laundering Authorities, particularly regarding whether to resume or suspend a particular transaction or keep a particular account active.

e – Electronic transactions executed for the customer are compared and assessed against the anticipated account turnover, the normal turnover from the customer’s activities/operations, and the data and information maintained in the customer’s economic profile.

f – Significant deviations are investigated and the findings are recorded in the respective customer file.

g – Transactions that are not justified by the information available about the customer are thoroughly examined to determine whether suspicion of money laundering or terrorist financing arises. If so, a report will be submitted to the Compliance Officer and subsequently to the relevant Money Laundering Authorities.

5.5 – Daily / Monthly Procedures of the AML Compliance Officer

The procedure to be followed by the AML Compliance Officer on a daily/monthly basis is as follows:

i – Receive a daily report from staff members regarding any suspicious transaction.

ii – Examine the reports submitted, if any.

iii – Report to Senior Management and advise on the need to take any of the following actions.

iv – Stop transactions if the reports are under review.

v – Inform the customer of the reasons why their transaction was cancelled.

vi – Collect transaction information if the transaction has already been executed.

vii – Report the suspicious transaction to the appropriate authorities as required by law.

The Company ensures that its employees are fully aware of their legal obligations under money laundering and terrorist financing prevention laws through a comprehensive employee education and training program.

The training program aims to educate employees about the latest developments in the prevention of money laundering and terrorist financing, including the practical methods and trends used for this purpose.

The training program ensures that the Company’s employees are fully aware that they may be personally liable for failing to report information or suspicions concerning money laundering or terrorist financing. The timing and content of training provided to employees in various departments are adjusted according to the needs of each department.

The frequency of training may vary according to changes in legal and/or regulatory requirements, employees’ obligations and any other changes in the financial system.

The structure of the training program will be aligned with the needs and the various functions of new employees, existing employees and the different departments of the Company.

Ongoing training is provided at regular intervals to ensure that employees are reminded of their duties and responsibilities and kept informed of any developments.

Any personal information collected about the customer, such as name, address, date of birth and contact details, will be maintained by Rocktrading Ltd strictly for business purposes. Other information, such as customer transactions, copies of passports and proof of address, will remain confidential and will be shared only among our account services and compliance departments. In addition, Rocktrading Ltd may inquire into the customer’s creditworthiness, which will also remain confidential within our customer files. Such information may be maintained physically or electronically subject to strict access procedures.

Rocktrading Ltd may share customer information with internal departments or affiliated offices that perform marketing, back-office and customer service functions in order to conduct normal business operations. Every employee within Rocktrading Ltd has signed a Confidentiality Agreement, as customer information is required to be kept confidential.

Any questions or requests for additional information regarding our privacy policy may be directed to our Customer Service Department at info@rocktradingltd.com.

The Client acknowledges and agrees to Rocktrading’s procedures for depositing and withdrawing funds from the accounts set forth below:

i – Withdrawal Orders: Providing any documentation that may be required from time to time under applicable anti-money laundering regulations, by credit card companies, or by Rocktrading is a mandatory requirement prior to the execution of a withdrawal order.

ii – The Client acknowledges that withdrawals may take longer than expected for various reasons, some of which are within Rocktrading’s control and others which are not.

iii – Credit card deposits may, in accordance with the applicable credit card regulations, be refunded to the same credit card when a withdrawal is made. If the initial deposits were made by credit card, a withdrawal to a bank account may be processed either to the credit card or to the bank account, at Rocktrading’s discretion. Withdrawals to a bank account may take longer due to additional security procedures.

iv – Credit Card Deposit Variations: When the account currency selected is different from USD, the Client’s credit card may be charged amounts that, due to exchange rates and credit card company fees, may vary slightly from the original amount deposited by the Client in the account’s base currency. The Client accepts that such variations may occur and hereby confirms that they will not dispute or seek to recover such difference.

v – When depositing funds by bank transfer, in compliance with anti-money laundering requirements, the Client must use a bank account located in their country of residence and held in their own name. Any withdrawal of funds from the Client’s Rocktrading account to a bank account may only be credited to the same bank account from which the funds were originally deposited.

vi – Alternative Payment Methods (online payment services, money transfer services, etc.): When funds are deposited using a method other than credit cards and/or banks, the Client agrees to be bound by the rules and regulations of such service, including, but not limited to, applicable fees and other restrictions. Rocktrading, at its sole discretion, may process withdrawals through a channel different from the one used for the original deposit, in accordance with applicable anti-money laundering regulations.

Rocktrading Ltd, committed to protecting your personal data and assuming responsibility for its use, handling and confidentiality in accordance with the provisions of the Federal Law on Protection of Personal Data Held by Private Parties, hereby issues this Privacy Notice in order to inform you of the main characteristics of the processing to which your personal data will be subject.

For the purposes set forth in this Privacy Notice, Rocktrading Ltd will collect the following information directly:

• Identification data, including your image.

• Immigration data.

• Contact data.

• Location data.

• Employment data.

• Academic data.

• Asset and/or financial data.

• Geolocation.

Likewise, Rocktrading Ltd may collect such personal data indirectly if it is provided to us by companies and/or other third parties with whom Rocktrading Ltd has entered into commercial agreements.

Rocktrading Ltd may process identification and contact data of third parties in order to validate the information you have provided and, where applicable, provide you with the corresponding benefits when such third parties are beneficiaries. By providing this information, you acknowledge that you have informed such third parties about the use of their data and have previously obtained their consent.

Due to the nature of Rocktrading Ltd’s products and services, we may collect information relating to minors or persons subject to legal incapacity. The processing of such data will only be carried out when the consent of the parent, mother or legal guardian has been obtained for the purposes set forth in this Privacy Notice.

In order to provide you with our products and services, Rocktrading Ltd will collect the following categories of sensitive personal data:

• Biometric data.

• Data concerning your health status.

Rocktrading Ltd will process the personal data described in this Privacy Notice for the following primary purposes:

• To comply with the contractual relationship arising from the application for and/or contracting of our products or services.

• To verify, confirm and validate your identity.

• To administer, operate and follow up on the services and products requested or contracted with Rocktrading Ltd.

• To provide you with access to the Rocktrading Ltd platform and applications, as well as the functionalities offered therein.

• To send you notifications containing information about the products or services contracted. This may include communications by email, telephone calls, text messages, and other physical, electronic and/or digital means of communication.

• To identify and prevent potential unlawful conduct that could constitute a violation of applicable laws and regulations.

• To conduct internal and external audit processes.

• To comply with obligations established by applicable legislation and competent authorities.

Likewise, unless you object, Rocktrading Ltd may process your personal data for the following secondary purposes:

• To send you offers, promotions and advertising regarding our products and services.

• To contact you to invite you to participate in programs, activities and events organized by Rocktrading Ltd, including tests intended to improve our products and/or services.

• To create customer profiles for the offering of products and services.

• To conduct surveys.

If you do not wish Rocktrading Ltd to process your personal data for any of the purposes described in this section, you may request this by sending an email to: info@rocktradingltd.com.

Rocktrading Ltd may transfer your personal data to both domestic and foreign entities without requiring your consent in the following cases:

• To the National Electoral Institute (Instituto Nacional Electoral) to validate your identity.

• To business partners with whom contracts have been entered into for the marketing of products and/or services, for the benefit and/or interest of customers, as well as to determine whether you are eligible to acquire the goods and/or services we offer.

• To courier and messaging companies for the delivery of communications related to the products and/or services contracted.

• To competent authorities in cases provided for by law.

You or your legal representative may exercise any of the rights of access, rectification, cancellation or objection, as well as withdraw your consent to the processing of your personal data, by sending an email to: info@rocktradingltd.com.

Your request must be submitted through the ARCO Rights Request (the "Request"), which is available on the website www.rocktradingltd.com and contains all the elements necessary to process your request in accordance with applicable regulations.

In order for Rocktrading Ltd to follow up on the Request, you or your legal representative must properly prove your identity; therefore, a copy of a valid official identification document must accompany the Request.

If the information provided in the Request is incorrect or insufficient, or if the corresponding identity documents are not provided, within five (5) business days following receipt of the Request, Rocktrading Ltd may request that you provide the necessary information or documents to process it. You will have ten (10) business days to respond to such request, beginning on the day following receipt thereof. If you fail to respond within that period, the corresponding Request will be deemed not to have been submitted.

Rocktrading Ltd will communicate its determination within a maximum period of twenty (20) business days from the date on which the Request was received, so that, if applicable, you may enforce the determination within the following fifteen (15) business days after the response has been communicated. The response will be provided through the means or channel specified in your Request.

You may limit the use or disclosure of your personal data by sending an email to: info@rocktradingltd.com. The requirements for proving your identity, as well as the procedure for processing your request, will be governed by the same criteria set forth in the preceding section. If your request is deemed admissible, Rocktrading Ltd will register you on its own exclusion list.

Rocktrading Ltd reserves the right, at its sole discretion, to change, modify, add or remove portions of this Privacy Notice at any time. In such case, Rocktrading Ltd will keep the complete and current Privacy Notice in effect on the website info@rocktradingltd.com.

We recommend that you visit this page periodically in order to be informed of any changes.

These Terms and Conditions form an integral part of the contractual relationship arising from the Specialized Services Agreement entered into between the parties, in accordance with applicable law.

Rocktrading Ltd acts solely as an intermediary, facilitating the connection between Users and various Payment Service Providers (PSPs) for the purpose of offering multiple alternatives for payment management.

It is important to emphasize that Rocktrading Ltd is not a financial institution, and the services it provides to Users do not, under any circumstances, include legal, tax, financial or accounting advice.

It shall be the Client’s responsibility to obtain all information necessary regarding transactions involving foreign currencies, CFDs, options and spread bets, and to ensure that all risks and provisions are clearly understood before undertaking any activity.

To use the Platform provided by Rocktrading Ltd, the User must create an account, which must be selected taking into consideration the User’s interests, objectives and trading profile.

Rocktrading Ltd reserves the right to offer different types of accounts with individual characteristics, as well as to modify, at any time, the requirements for access to each type of account or to withdraw any option from its catalogue, with prior notice through authorized channels.

If the User fails to provide the requested documentation within seven calendar days, Rocktrading Ltd may suspend withdrawals and temporarily block the Account until the required information is received.

The sole means of contact between Rocktrading Ltd and the User shall be the email address used for the User’s initial registration on the Platform.

This channel will be used to contact the User and provide all information relating to the User’s account, summaries of transactions carried out, information, announcements and/or promotions.

To ensure that information is sent correctly, Rocktrading Ltd shall maintain an internal protocol to verify compliance with the steps necessary for the proper delivery of information. The User shall be responsible for ensuring that their account remains active, that their email address was entered correctly during registration, and that the address is capable of receiving emails sent by Rocktrading Ltd.

If any issue arises regarding this means of communication, the User shall be responsible for contacting Rocktrading Ltd’s customer service department so that assistance can be provided and the User’s information can be corrected.

From the commencement of the commercial relationship between Rocktrading Ltd and the User, the User shall be solely and fully responsible for complying with the obligations applicable to them under this document. This includes, without limitation, the truthfulness, completeness and updating of the information and documentation provided; compliance with applicable tax provisions; payment of taxes arising from transactions conducted through the Platform; and the timely submission of tax returns and reports to any competent governmental or other authority where required by applicable law.

The User undertakes to:

• Provide truthful and complete information.

• Use the services for lawful purposes and refrain from carrying out fraudulent or illegal transactions, or transactions that may raise suspicions regarding the activities being conducted.

• Comply with applicable provisions on Anti-Money Laundering and Countering the Financing of Terrorism.

• Comply with all legislation applicable to the User.

In the event that the User breaches any of the provisions established above or any provisions that may subsequently arise, Rocktrading Ltd may take the measures permitted under the applicable contractual and legal framework.

The User assumes full responsibility for any errors in the payment information provided to Rocktrading Ltd. The User also accepts that Rocktrading Ltd may be unable to process withdrawal requests when the requested amount is below the minimum established by the payment service provider.

Likewise, if the Account is blocked, Rocktrading Ltd may carry out forced withdrawals or reject withdrawal requests where the available balance is below the applicable minimum amount.

The User represents and warrants that all information provided to Rocktrading Ltd is truthful, complete and accurate. The User further undertakes to immediately notify Rocktrading Ltd of any material change to such information, including, without limitation, changes to contact details, address or financial circumstances.

If identification documents provided by the User are modified or expire, the User must notify Rocktrading Ltd within a maximum period of three business days from the date of such modification or expiration. Such notification must be made in writing, duly signed, scanned and sent from the email address registered by the User on the Platform. The notification must include the modified document bearing its most recent issue date.

Rocktrading Ltd reserves the right to restrict, suspend, block or cancel access to the Platform at any time where there are reasonable indications or suspicions that information or documentation provided by the User is false, inaccurate, incomplete or fraudulent.

Rocktrading Ltd reserves the right not to open accounts for Users who are citizens or residents of the following countries:

Afghanistan; Cuba; Eritrea; European Union; Honduras; Iceland; India; Iran; Iraq; Kazakhstan; Libya; Liechtenstein; Myanmar; North Korea; Russian Federation; Serbia; South Korea; South Sudan; Sudan; Syrian Arab Republic; United Kingdom; United States of America.

Likewise, Rocktrading Ltd reserves the right not to establish commercial relationships with or execute transactions for Users presenting any of the following profiles:

• Individuals who are citizens or residents of any of the countries previously listed by Rocktrading Ltd.

• Individuals who do not have the legal capacity required under applicable law to exercise their rights and assume obligations.

• Persons who refuse, omit or fail to provide information and/or documentation requested by Rocktrading Ltd for the purpose of verifying their identity.

• Individuals or legal entities providing money/value transfer services, including those engaged in money services or similar activities.

• Persons with criminal records, regardless of the nature or age of the offense.

Rocktrading Ltd may also, at any time and at its sole discretion, terminate the provision of its services and products to Users without being required to state a reason or provide prior notice.

The Platform serves as the link between Users and the various Payment Service Providers, which are responsible for processing payments. Rocktrading Ltd’s activity is therefore limited to issuing payment instructions submitted by the User. Execution and processing times depend exclusively on the Payment Service Provider.

The contractual relationship between the parties shall commence when the User creates an account through the corresponding section of the Platform.

To create the account, the User must provide a valid email address, which must subsequently be verified. Once this step is completed, the User must undergo an identity verification process and provide truthful, complete and up-to-date personal information, together with all documentation required under the "Know Your Customer" (KYC) procedure.

Where a minimum deposit requirement has been established for Account activation, the User must satisfy that requirement before Rocktrading Ltd enables access to the Account and its use.

The applicable minimum deposit shall be the amount in force and published on the Rocktrading Ltd Website at the time the Account opening request is submitted. Such amount may be modified in accordance with the applicable Terms and Conditions.

Once the verification process has been successfully completed, the Account may be considered verified. Each User may have only one verified account. Full compliance with the requirements described above is an essential condition for obtaining full access to the functionalities and services available on the Platform.

When creating an account, Users are advised to open only one account per mobile device. If multiple Users have accounts open on the same device, all orders issued from one of the registered accounts will be executed in the same manner for the other active accounts on that device.

For the User to conduct transactions on the Platform, Rocktrading Ltd’s Trading Department shall be responsible for granting access to the Platform.

The account holder is the only person authorized to issue payment orders through the Platform, unless otherwise provided.

For an order to be considered valid, it must be correctly registered by Rocktrading Ltd and contain the acceptance confirmation issued by the Platform. In accordance with the agreement between the parties, the Platform is the sole valid and recognized means for issuing and validating such orders.

Once the User has carried out a transaction, if the User does not receive a confirmation of the order issued, it shall be the User’s sole responsibility to contact Rocktrading Ltd and report the matter.

Rocktrading Ltd shall not be liable for interruptions, failures or communication errors that occur or may occur before the User is able to access or execute transactions on the Platform.

If situations arise in which errors occur in the issuance of an order, Rocktrading Ltd shall not be responsible for the resulting consequences unless such matter falls within Rocktrading Ltd’s applicable responsibilities.

If the User places an order through the Platform and the Platform does not issue a confirmation for such request, it shall be the User’s sole responsibility to contact Rocktrading Ltd promptly to request the relevant confirmation.

To provide security to Users, Rocktrading Ltd shall send transaction summaries through authorized electronic means. The User is solely responsible for reviewing such reports to verify that the information is correct and, if it is not, the User shall have two business days after receipt of the information to submit any clarification or dispute regarding such information.

Upon registering on the Platform, the User must create a username and personal password. Such credentials are strictly confidential, personal and non-transferable and must be safeguarded with due diligence by the User. The User assumes full responsibility for all actions or transactions carried out through the Account, whether resulting from the User’s own actions or from misuse by a third party.

The User undertakes to immediately notify Rocktrading Ltd of any unauthorized use of their credentials or any incident that may compromise the security of the Account.

Through the Platform, the User may make deposits and withdrawals of funds at any time during the term of this agreement, using any payment methods enabled on the Platform.

Minimum and maximum deposit and withdrawal amounts, as well as applicable fees, shall be available in the corresponding section of the Website and may be modified by Rocktrading Ltd at any time without prior notice.

Rocktrading Ltd shall not accept payments from third parties and shall not make deposits to anonymous accounts. As a general rule, funds must be withdrawn using the same method used for the deposit, unless there is a duly justified reason and Rocktrading Ltd has expressly authorized an alternative.

For deposits, Rocktrading Ltd shall credit the funds to the User’s Account as soon as reasonably possible after the amounts have been received and cleared. If the funds are not correctly reflected, the User must notify Rocktrading Ltd immediately and may request an investigation, the costs of which shall be borne by the User. The User also undertakes to provide all documentation requested for that purpose.

If the User uses multiple payment methods, withdrawals shall be made using proportionality criteria defined by Rocktrading Ltd. Rocktrading Ltd may also determine the order in which reimbursements are made, at its sole discretion.

Rocktrading Ltd shall process withdrawal requests without undue delay and, where reasonably possible, within a maximum period of three business days, provided that: (a) the withdrawal request is complete and contains all required information; (b) the withdrawal is requested to the same account used for the deposit, or another account owned by the User that has been duly verified; (c) the User has sufficient funds in the Account; (d) no force majeure event prevents execution; (e) the User has satisfactorily completed KYC requirements; (f) the Account is not blocked or subject to sanctions or contractual restrictions; and (g) Rocktrading Ltd does not authorize withdrawals in favor of third parties or to anonymous accounts. If a withdrawal is requested to an account other than the original account, the User warrants that the account belongs to them and assumes full responsibility for the information provided, releasing Rocktrading Ltd from liability arising from errors in the information supplied.

In order to provide the highest level of security and protection to Platform Users, Rocktrading Ltd may, at its sole discretion: (a) reject withdrawal requests; (b) establish minimum or maximum limits; (c) propose alternative payment methods; and (d) request additional documentation.

If the User fails to provide requested documentation within seven calendar days, Rocktrading Ltd may suspend the withdrawal and temporarily block the Account until the requested information is received.

If the Account is closed, funds shall be returned proportionally according to the payment methods originally used, unless there are indications of illegal activity, in which case Rocktrading Ltd shall act in accordance with applicable regulations and may notify the competent authorities.

For deposits made by bank card, funds may be returned to the same card for a maximum period of one calendar year. After that period, alternative methods for withdrawals shall be proposed.

Rocktrading Ltd reserves the right to establish minimum and maximum amounts for deposits and withdrawals in accordance with the conditions imposed by Payment Service Providers. Requests that do not meet the applicable minimum amounts may be rejected. Funds sent in error or through unsupported methods may be non-refundable and may be considered lost without a right to claim.

The User acknowledges that there is a risk of loss of funds if the amount deposited is below the minimum required by Rocktrading Ltd or by the relevant Payment Service Provider.

Rocktrading Ltd reserves the right to request, at any time, additional information and/or documentation to verify the lawful source of funds in accordance with applicable Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) regulations.

Such documents may include, without limitation: proof of income; identification documents; proof of address; and video recordings with valid identification.

During this verification process, Rocktrading Ltd may temporarily suspend Account operations for up to fourteen calendar days. Rocktrading Ltd may also reject deposits or withdrawals if the verification results are not satisfactory under its internal compliance policies.

Rocktrading Ltd allows Users to make internal transfers of funds to another account, provided that the receiving account is enabled to make and receive deposits and withdrawals. To make such a transfer, the account must belong to the same User, or, if it belongs to a different User, the transfer amount must exceed the initial minimum.

The User must provide all information necessary to make the internal transfer. If any information supplied by the User is incorrect and the transfer is consequently made to an incorrect account, the User shall assume full responsibility and may not request a refund of the funds from Rocktrading Ltd.

The User may request an internal transfer, but Rocktrading Ltd retains full discretion to reject such transfer without providing a reason.

If a chargeback, whether intentional or accidental, occurs in relation to a deposit made by the User, Rocktrading Ltd reserves the right to debit the chargeback amount from the User’s Account. Such amount shall remain frozen until a final resolution is issued by the card issuer.

Once the issuer has reached a decision and determines that the deposited amount must be refunded, Rocktrading Ltd shall be entitled to charge the User’s Account an amount of USD 100 corresponding to administrative costs associated with investigating the chargeback request. The User authorizes such charge to be made to the credit card used for the initial deposit to open the Account.

Once a chargeback request is submitted, Rocktrading Ltd shall request the User’s cooperation in resolving the dispute arising from the unrecognized deposit. If the User fails to cooperate, or if Rocktrading Ltd detects suspicious activity, it may apply anti-fraud controls and restrict access to the Account.

Rocktrading Ltd maintains a zero-tolerance policy toward fraud, particularly fraud involving credit cards. The User is therefore informed that, if there is suspicion or evidence of fraud, Rocktrading Ltd may take civil or criminal legal action to obtain compensation for the damage caused by the User.

If any or all transactions conducted by the User are identified as fraudulent, Rocktrading Ltd may immediately cancel them and close open orders without prior notice.

Rocktrading Ltd may immediately cancel and return funds to their source if a deposit made by the Client is considered high-risk or fails to comply with established anti-fraud policies.

Rocktrading Ltd may deactivate and archive any Account that remains inactive for more than ninety calendar days. For purposes of this provision, an Account shall be considered active when any of the following occurs: (a) logging into the Platform; (b) changing Account settings; (c) making withdrawals; (d) executing transactions; or (e) any other transaction linked to the available balance.

The User may request reactivation of the Account through the area enabled for that purpose within the Platform.

Rocktrading Ltd (and, where applicable, none of its providers) shall not be responsible or liable for:

• Monitoring and/or tracking transactions carried out by the User.

• Closing open positions that have not been closed by the User.

• Executing orders issued by the User that do not match the quotations published on the Platform at the time the order is issued.

• Losses, damages or expenses arising from technical failures during data transmission, system errors, network congestion, and other fortuitous events arising from technical failures beyond Rocktrading Ltd’s control.

• Delays in sending or receiving information caused by delays, errors, omissions or inaccuracies in information shared through the Platform.

• The User, their devices or information suffering a digital threat despite our best efforts, including vulnerability to viruses, malware, software and similar threats.

• Misuse of credentials provided to the User, whether authorized or unauthorized. If such misuse causes harm to Rocktrading Ltd, the Account holder shall be responsible for such harm.

• Losses or damages incurred as a result of using the Platform or other services offered by Rocktrading Ltd.

• Misinterpretations or delays in execution resulting from unclear instructions, system interruptions or other circumstances outside Rocktrading Ltd’s control.

• Information published on the Platform shall not be construed as individualized advice.

• Effects arising from events such as natural disasters, armed conflicts, sabotage and similar events shall not create an obligation for Rocktrading Ltd.

• Economic losses, indirect damages, loss of data, reputational harm and similar losses, except where otherwise provided, including cases involving death, injury or fraud.

Any breach of the clauses contained in these Terms and Conditions shall entitle Rocktrading Ltd to take contractual measures, such as modification or suspension of the agreement, in the event of a dispute between the parties.

Rocktrading Ltd does not provide investment, tax, trading or other advice.

From time to time, Rocktrading Ltd may provide Users with information concerning financial market conditions for strictly educational and informational purposes. Such information shall not be interpreted as professional advice or a guarantee of results. The User must be aware that decisions should be made based on their own analysis and consultation with independent and reliable sources.

Any suggestion, comment or recommendation that Rocktrading Ltd may issue shall be considered general guidance only, with no binding effect, and its adoption shall remain solely at the User’s discretion.

Rocktrading Ltd assumes no liability for losses, damages, penalties or other adverse effects resulting from the use or interpretation of information provided, as such information is strictly informational and non-binding.

Likewise, Rocktrading Ltd’s representatives and collaborators are not authorized to provide investment advice, portfolio management, algorithmic services, execution of automated strategies, fund management or similar activities.

All decisions made and transactions carried out by the User shall be made at the User’s own account and risk, and Rocktrading Ltd is not required to: (a) assess the suitability or appropriateness of contracts entered into by the User; (b) supervise the status or development of transactions; or (c) make margin calls or close open positions on behalf of the User.

Accordingly, Rocktrading Ltd shall not be liable for direct, indirect or consequential losses suffered by the User as a result of the User’s decisions or activities on the Platform.

Our services are limited exclusively to "execution"; our role is limited to executing transactions submitted by Users. No advice shall be provided regarding any transaction, nor shall Rocktrading Ltd supervise the User’s trading decisions to determine whether they are suitable or appropriate. Users are strongly advised to seek professional financial, legal, tax and other advice in order to make informed decisions with appropriate support.

The User expressly and irrevocably consents to Rocktrading Ltd:

• Recording conversations held between the User and Rocktrading Ltd without requiring separate express consent or a distinctive recording tone.

• Recording and storing communications conducted between the User and Rocktrading Ltd through its various communication channels.

• Using, where necessary, any recording, transcription or record of communications between Rocktrading Ltd and the User for a lawful purpose, including in legal proceedings.

In the event of a dispute between the parties, the User may request access to the relevant recordings. However, this document does not impose any obligation on Rocktrading Ltd to inform the User about the retention or deletion of such recordings or records.

All recordings made shall be the exclusive property of Rocktrading Ltd and shall constitute valid, sufficient and binding evidence before any administrative, judicial or arbitral authority when their production is required.

The User acknowledges and accepts that promotions offered by Rocktrading Ltd may be conducted periodically and shall be subject to the terms and conditions applicable to each promotion. Rocktrading Ltd is also entitled to remove, suspend or terminate any promotion at any time at its discretion and without prior notice.

Rocktrading Ltd reserves the right to suspend, exclude or reject any User from one or all promotions where it has suspicions or indications that the User, individually or together with third parties, is attempting to manipulate the promotion or engage in criminal or bad-faith conduct. Accordingly, Rocktrading Ltd may take the necessary measures to suspend, block or cancel, temporarily or permanently, the services, Account, benefits, bonuses or advantages.

If such conduct results in the User obtaining a benefit, Rocktrading Ltd shall be entitled to withhold any profits or benefits generated by the User through such conduct.

In order to comply with applicable legal requirements, Rocktrading Ltd may collect documentation relating to the User and/or their transactions in accordance with AML/CTF legislation, its regulations and other applicable rules.

Rocktrading Ltd may also carry out any verification it considers necessary in relation to the prevention of money laundering or other unlawful activities. Accordingly, Rocktrading Ltd reserves the right to adopt any measure it considers appropriate to ensure compliance with applicable regulations, without incurring liability as a result.

The User acknowledges and agrees that Rocktrading Ltd may request, at any time, certain information for the purpose of complying with applicable AML/CTF requirements. Both upon opening the Account and when carrying out transactions, the User undertakes to provide Rocktrading Ltd with all information, documentation and cooperation necessary to comply with applicable AML/CTF provisions.

The Client represents and warrants that:

• They have no knowledge or suspicion that the funds used for their transactions originate from or are related to money laundering, terrorist financing or other unlawful conduct prohibited by applicable law, international law, treaties or conventions.

• Their financial resources are not intended, directly or indirectly, to finance illegal activities.

Acceptance of each and every clause and section contained in this document is essential in order for the User to receive optimal service and functionality from the Platform and its services. The User is strongly encouraged to read and understand these Terms and Conditions, Privacy Notice, Risk Policy, Disclaimer, Cookie Policy, KYC (Know Your Customer), Anti-Money Laundering Policy and Beneficial Owner Form (all included in the legal documentation package), as well as the DOD, where applicable.

When the User accesses the Platform and subsequently uses one or more of our services, this document and all other documents arising from the contractual relationship between the parties shall be deemed accepted. Unless the User has communicated an objection to Rocktrading Ltd, all provisions contained in the legal documentation package shall be deemed accepted.

Rocktrading Ltd may terminate the agreement and suspend the contracted service whenever it deems appropriate.

The User shall be solely responsible for complying with all obligations arising from the commencement of the commercial relationship.

The latest updated version of this document and subsequent versions shall be available on our Platform.

Rocktrading Ltd is entitled to partially or fully amend these Terms and Conditions. Such amendments shall become effective upon publication on its website. The amendments shall apply to all open positions without exception, including those that have not been executed. In the event of force majeure, the User shall be notified ten days in advance.

Termination of these Terms and Conditions and the Account Closure Agreement may take effect immediately, including the closure of any open position at the time of notification, provided that at least five days’ prior notice has been given. Termination may occur if any of the following circumstances arises:

• Breach by the User of any obligation arising under this Agreement or related documents.

• Acts or omissions contrary to the provisions of this agreement.

• Making statements or carrying out acts that directly or indirectly harm the reputation, operations or commercial relationships of Rocktrading Ltd.

• Being charged with an offense that causes reputational or legal harm to Rocktrading Ltd.

• Investigation of the User by a governmental or international authority in connection with transactions carried out on the Platform.

• Prolonged failure to comply with the Margin Requirement.

• Breach of any other contractual provision.

• Falsehood of any representation or warranty made under these Terms and Conditions.

The foregoing shall not affect rights already acquired by Rocktrading Ltd or its right to claim any applicable compensation arising from termination. In such case, Rocktrading Ltd shall be entitled to:

• Suspend or cancel the User’s Account and restrict or deny access to the Platform.

• Make any adjustments it considers appropriate to the Account.

• Liquidate pending contracts that have not been timely executed.

• Enter into new contracts if necessary to close existing ones.

• Cancel active purchase and/or sale orders.

• Temporarily suspend deposits and withdrawals.

• Limit or disable available payment methods.

• Retain amounts related to contractual breaches.

• Exercise any right provided for in these Terms and Conditions.

If termination of the agreement or closure of the Account is requested by the User or by Rocktrading Ltd, no new transactions may be opened and no open positions may be maintained after written notice. The User must close all positions; if the User fails to do so, Rocktrading Ltd shall proceed with the corresponding closure.

Death or Incapacity of the User

In the event of the User’s death or legal incapacity, Rocktrading Ltd may terminate the agreement and block the Account. Funds may only be withdrawn by the legal heirs, who must provide documentation proving their entitlement. Under no circumstances may they operate the Account or access the Platform.

Amendments to the Terms and Conditions

Rocktrading Ltd reserves the right to modify these Terms and Conditions and the applicable legal documents at any time. Amendments shall become effective upon publication on the website and shall apply to both active transactions and pending orders. Except in urgent cases, the User shall be notified at least ten business days in advance. Continued use of the services shall constitute tacit acceptance of such changes. If the User disagrees, the User must communicate such disagreement within the same period.

Effects of Rescission

Termination of the agreement shall not release either the User or Rocktrading Ltd from obligations previously incurred, including open transactions, movement of funds or other outstanding liabilities. The User shall pay any outstanding balance and costs arising from termination, as well as any damage caused. Once the relevant adjustments have been made, Rocktrading Ltd shall transfer the available funds in the User’s Account, less any outstanding amounts.