Privacy Policy

We, at Crypto Theorem recognise and respect the importance of protecting the privacy of visitors to our website. This privacy policy explains what information we collect about you through our website, how we use that information and the procedures that we have in place to safeguard your privacy.

We reserve the right to amend or modify this privacy policy at any time and in response to changes in applicable law. If we change our privacy policy we will post the changes on this page, and may place notices on other pages of our website, so that you are aware of any amendments.

Collection of Personal Information

We collect certain personal information from you when you set up or update an account or other registration on our website or online platforms or otherwise when you use the services available through our website (“Services”) in order to facilitate the provision of the Services and to maintain our quality standards. These details may include, without limitation, your name, address, contact details. You can amend or update the information you have entered into the website at any time. The security of your data whilst it is being transmitted to or from our site; any transmission is at your own risk. Personal data will be held by Crypto Theorem using appropriate safeguards to maintain its privacy and security.

Use of Personal Information

We use information held about you to provide you with information, products or services that you request from us.

By registering your details on the website, you consent to us contacting you via email, telephone or post, for the purposes of:

• monitoring the provision of the Services through the website;
• providing you with relevant information pertaining to the Services on our website;
• compliance with legal obligations, or protection and enforcement of legal rights;
• managing actual or potential business transactions (e.g. in the case of an acquisition of Crypto Theorem’s business); and/or
• provided that you “opt in” to receiving such communications, we may send you promotional emails about our own or third parties’ new products or special offers, or other information which we think you may find interesting. We may also contact you for market research purposes.

If you have previously consented to us using your personal information for direct marketing purposes, you may change your mind at any time by notifying us by email or by post using the contact details below.

When you provide feedback in relation to the service, you will be given the option of keeping your identity secret from other users.

Disclosure of Personal Information

Crypto Theorem may disclose your personal data for the purposes outlined to third parties, including:

• our service providers and professional advisers;
• governmental bodies and law enforcement authorities;
• any investor, lender, purchaser or (on terms of confidentiality) likely investor in, or purchaser of Crypto Theorem’s business; and
• other third parties where required or permitted by law.

We will not share, trade or sell your information to any company or parties not directly associated with its proper use within the website or as described above, except when you give us explicit permission and we give you an opportunity to opt out of having your personal information shared. In certain circumstances, we may have a legal obligation to disclose personal information, and we reserve the right to do so.

Storage and security of your personal data

Your personal data is stored in electronic and physical records maintained by Crypto Theorem and/or its service providers. Whilst Crypto Theorem is based in the UK, it and its service providers may have servers located outside the European Economic Area ("EEA"), where the laws may not give the same level of protection to personal data as within the UK. By submitting your personal data, you agree to allowing your personal data to be transferred, processed and stored overseas as set out in this paragraph.

Data that we collect from you may also be processed by persons operating outside the EEA who work for us or for one of our suppliers. Such persons may be engaged in, among other things, the provision of certain services which support our website and allow us to provide the Services to you. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Access to your details

If you would like to access a copy of any personal data which Crypto Theorem holds about you, please send a request by email or by post using the contact details in paragraph 9 below. For security reasons we may ask for proof of your identity before we disclose information about you, or to you, via email or over the telephone.

You have the right, in certain circumstances, to object to Crypto Theorem processing your personal data or to request that your personal data is corrected or deleted. Please contact us using the contact details in paragraph 9 below.

Collection of Technical Data and Cookies

We reserve the right to collect technical data about the type of browser software or operating system you are using for the purposes of tracking website use, or improving the service offered through our website. This information will be not used to identify you personally.

We may also place a 'cookie' on your browser to provide us with information about your use of the site, and to help us identify you when you return to the site so that your preferences can be stored. Using cookies helps us to improve our website and to deliver a better and more personalised service. We may also use cookies to identify repeat visitors.

You can remove cookies from your computer at any time, and choose to disable cookies in your internet browser settings.

Contact information

We do not publicly display any contact details or other sensitive information on our site. All communication takes place securely through the website.

Phone Calls

Please note that calls may be recorded for training and monitoring purposes.

Queries

If you have any queries in relation to the processing of your personal data by Crypto Theorem, please contact us:

By email: support@cryptotheorem.com

Disclaimer

The cryptotheorem.com web site is published as an informational service for subscribers by Crypto Theorem, Inc., and it includes opinions as to buying, selling and holding various securities. The publishers of cryptotheorem.com are not investment advisers, and they do not provide investment advice or recommendations directed to any particular subscriber or in view of the particular circumstances of any particular person. The information provided by cryptotheorem.com is obtained from sources believed to be reliable but is not guaranteed as to accuracy or completeness. Subscribers to cryptotheorem.com or any other persons who buy, sell or hold securities should do so with caution and consult with their financial advisor.

The publishers of cryptotheorem.com may buy or sell the securities discussed for purposes of investment or trading without disclosure of all trades to subscribers. cryptotheorem.com and its publishers, owners and agents, are not liable for any losses or damages, monetary or otherwise, that result from the content of cryptotheorem.com. Securities discussed by cryptotheorem.com should be considered speculative and contain a high degree of volatility and risk.

The information contained on cryptotheorem.com is provided for general informational purposes, as a convenience to the subscribers of cryptotheorem.com. The materials are not a substitute for obtaining professional advice from a qualified person, firm or corporation. Consult the appropriate professional advisor for more complete and current information. cryptotheorem.com is not engaged in rendering any legal or professional services by placing these general informational materials on cryptotheorem.com. cryptotheorem.com and its publishers specifically disclaim any liability, whether based in contract, tort, strict liability or otherwise, for any direct, indirect, incidental, consequential, or special damages arising out of or in any way connected with access to or use of cryptotheorem.com, even if cryptotheorem.com has been advised of the possibility of such damages, including liability in connection with mistakes or omissions in, or delays in transmission of, information to or from the user, interruptions in telecommunications connections to the site or viruses.

cryptotheorem.com makes no representations or warranties about the accuracy or completeness of the information contained on this website. Any links provided to other server sites are offered as a matter of convenience and in no way are meant to imply that cryptotheorem.com endorses, sponsors, promotes or is affiliated with the owners of or participants in those sites, or endorses any information contained on those sites, unless expressly stated. However, cryptotheorem.com may receive compensation from the server sites which are provided through links. cryptotheorem.com is the copyright owner of all text and graphics contained on this website, except as otherwise indicated. Other parties' trademarks and service marks that may be referred to herein are the property of their respective owners. You may print a copy of the information contained herein for your personal use only, but you may not reproduce or distribute the text or graphics to others or substantially copy the information on your own server, or link to this website, without prior written permission of cryptotheorem.com. Permission to use and reproduce documents and related graphics available from this website is granted, provided that: (1) the below copyright notice appears in all copies and that both the copyright and this permission notice appear; (2) use and reproduction of documents and related graphics available from this website is limited to personal, non-commercial use; (3) no documents or related graphics, including logos, available from this website are modified in any way; and (4) no graphics, including logos, available from this website are used separate from accompanying text. Use or reproduction for any other purpose is expressly prohibited by law, and may result in civil and criminal penalties. Violators will be prosecuted to the maximum extent possible.

OTHER THAN AS SET FORTH ABOVE, ANY REDISTRIBUTION of the cryptotheorem.com web site or the information contained therein, without the written consent of the publishers of cryptotheorem.com, is STRICTLY PROHIBITED. Copying and/or electronic transmission of the cryptotheorem.com web site or content is a violation of copyright law.

If you have any questions or concerns, please do not hesitate to contact us.

By email: admin@cryptotheorem.com

Affiliate Policy

This Affiliate Program Agreement (“Agreement” or the “CryptoTheorem’s Affiliate Program“) is made by and between CryptoTheorem Limited (together with its Affiliated Corporation (as defined below) “CryptoTheorem“) and any person or entity executing the registration form (the “Enrollment Form“) set forth in the registration page located at cryptotheorem.com (the “Affiliate” or “You“).

By executing the Registration Form You are deemed to have agreed to be bound by all the terms and conditions set out in this Agreement as may be amended from time to time.

PLEASE READ THE TERMS AND CONDITIONS OF THIS AGREEMENT CAREFULLY BEFORE EXECUTING THE REGISTRATION FORM.

By participating in CryptoTheorem’s Affiliate Program You hereby accept the terms and conditions of this Agreement as may be amended from time to time. If You do not agree to such terms and conditions and/or any amendment thereto, please do not participate in, use, or access to CryptoTheorem’s Affiliate Program. Please note that CryptoTheorem reserves the right, at its sole discretion, to revise, modify, change or remove portions of this Agreement at any time. Please check periodically the terms and conditions of this Agreement on CryptoTheorem’s internet website to review any changes to its terms. Your participation in eToro’s Affiliate Program, after eToro has published on its websites any revised and/or amended form of this Agreement, shall constitute your consent to the revised and/or amended Agreement.

CryptoTheorem reserves the right, under its sole and absolute discretion, to reject the registration of any entity or person to CryptoTheorem’s Affiliate Program, including in the event that such entity is a person under the age of 18 or are defined as minors that have not yet reached legal age.

CryptoTheorem may elect to provide You with this Agreement and/or any other documentation, information and communications in various languages. By accepting this Agreement (in any of these languages) You acknowledge and confirm that CryptoTheorem’s official language is the English language, and in the event of any discrepancy or inconsistency between any documentation, information and communications in any language other than the English language and the same in the English language, the English documentation, information and communications shall exclusively prevail.

1 Definitions

For the purposes of this Agreement, the following terms shall have the meaning detailed next to them:

1.1. “Affiliate Network” means an Affiliate that operates, through the Affiliate Websites, a network of affiliates engaging in the marketing and promotion of online trading platforms.

1.2. “Affiliate Websites” means the internet websites operated by the Affiliate which shall contain the Link.

1.3. “Affiliated Corporation” means, with respect to any entity, any other entity, directly or indirectly, through one or more intermediary persons, controlling, controlled by or under common control with such entity, or, in respect of any entity which is a corporation, any other corporation being part of the same group of companies to which such corporation belong.

1.4. “Click” means, with respect to a bone fide visitor in the Affiliates Websites, the action of voluntarily pressing a Link in one of the the Affiliate Websites, in order to access to CryptoTheorem Websites and/or the Platforms.

1.5 “Customer” means any Lead conducting purchasing activities through the Platform. Such Lead shall exclude the Affiliate and/or any person or within the Affiliate’s single household, at our sole discretion. To the extent, any Fees have been paid in connection with any such excluded person may be deducted from the Affiliate’s Account.

1.6. “Customer Account” means an account opened with CryptoTheorem for each Customer, enabling the Customer to log into the Platform and to identify the activity of the Customer within the Platform.

1.7. “Confidential Information” means any data or information of either party, including oral, written or electronic data or information including past, present or future research, development or business activities, and including without limitation, any information relating to developments, inventions, processes, plans, trading information and financial information.

The Confidential Information shall not include information that is available in the public domain, not as a result of the actions of the receiving party, that was known to and/or developed by the receiving party prior to its receipt from the disclosing party, or that was lawfully received by the receiving party from a third party without obligation of confidence.

1.8. “CPA”/“Cost Per Acquisition”; “CPA” means a one-time fixed amount payable upon customer purchase.

1.9. “CPC”/“Cost Per Click” means a one-time fixed amount payable with respect to any unique entity/person that has clicked on a banner of CryptoTheorem on the Affiliate Websites;

1.10. “CPI”/“Cost Per Install” means a one-time fixed amount payable with respect to any entity that has firstly downloaded the Platform's application from the Affiliate Websites to his/her mobile device and/or tablet computer, that has fully installed such application and that has opened such application;

1.11. “CPL”/“Cost Per Lead” means a one-time a fixed amount payable with respect to any entity becoming a Lead;

1.12. “CPM”/“Cost Per Mille” means a one-time fixed amount payable with respect to each 1,000 Impressions (as defined below). "Impression" means each time CryptoTheorem's advertisement is displayed to a user while viewing a web page in the Affiliate Websites;

1.13. “Eligible Affiliate” means any Affiliate which: (a) has been attributed as an “affiliate” of CryptoTheorem pursuant to CryptoTheorem’s customary tracking protocols, including but not limited to, the use of CryptoTheorem’s unique affiliates’ identification code, cookies or otherwise, and (b) has been accepted by CryptoTheorem, under its sole and absolute discretion, and (c) has registered as CryptoTheorem’s “affiliate” on the Registration Page at cryptotheorem.com.

1.14. “CryptoTheorem Brands“ means all the trademarks, trade names, brand names and/or domain names owned and/or used by CryptoTheorem.

1.15. “CryptoTheorem Websites” means the Internet websites owned, maintained or operated by CryptoTheorem, which offer their users services including trading activities through the Trading Platform.

1.16. “FTD” means a Customer which generated a minimum amount of Net Revenues (using its own funds), in each case, within 90 days following the first deposit date. For the avoidance of doubt, it is clarified that: (a) any Lead which made an FTD and did not open and close at least one position or generated the minimum number of revenues as aforesaid within said 90 days shall not be considered an FTD and shall not entitle the Affiliate to a CPA commission; and (b) any Customer that already deposited funds into any account with CryptoTheorem and that thereafter made additional deposits into any account (including new accounts maintained under a single household/control/ownership) opened with CryptoTheorem, shall not be considered as FTD with respect to any deposit of funds which is not the first deposit. For the purpose hereof, CryptoTheorem may determine, in its sole discretion, that several accounts maintained under the same household/control/ownership shall be considered as a single account and shall not entitle the Affiliate to Fees payable with respect to separate accounts

1.17 “Intellectual Property Rights“ means any intangible right, title and interest, including any rights relating to or arising under copyright, trademark, patent, trade secret, moral rights, right of publicity, authors’ rights, and all other proprietary rights as may exist now and/or hereafter come into existence and all renewals and extensions thereof, under any application law or jurisdiction.

1.18. “Lead” means any person of a legal age in its country of residence or entity that has registered and logged in to the Platform, which is identified in CryptoTheorem’s computerized systems as a person or entity which firstly entered into CryptoTheorem Websites directly through the Link. Registration must be made for an account. Any person or entity shall be considered a “Lead” hereunder solely to the extent that: (a) the details provided by the Affiliate shall include at least the following: the full legal name of the person or entity, a email address; and (b) such person or entity originated from the country allowable under the relevant campaign and from a unique IP address; and (c) such person or entity has verified his account pursuant to CryptoTheorem’s procedures. Any person or entity entering into the Trading Platform through the Link after such person or entity already entered into CryptoTheorem Websites not through the Link shall not be considered as a Lead. Duplicate “Leads” will be disregarded.

1.19. “Lead/Customer Data” means any and all data submitted by the Lead/Customer to CryptoTheorem whether or not through the Platform and collected, compiled and stored by CryptoTheorem.

1.20. “License” means a nonexclusive, personal, non-transferable, non-assignable and non-sublicensable license, for the term of this Agreement, to promote and market CryptoTheorem’s services and/or the Trading Platform from the Affiliate Websites.

1.20. “Link(s)” means a link and/or links to CryptoTheorem Websites which the systems of CryptoTheorem shall create for the benefit of the Affiliate.

1.21. “Net Revenues” means, with respect to any calendar month, Subscription revenues in such month and Transaction Expenses in such month.

1.22 “Non-Qualified Traffic” means traffic from the Affiliate Websites and/or Leads/Customers and/or any deposit and/or Net Revenues generated by any Customer which CryptoTheorem has reason the believe in its sole and absolute discretion to: (i) have been obtained by illegitimate means (including without limitation to those relating to e-mail marketing and “spamming”); and/or (ii) be false and/or non-compliant with CryptoTheorem’s Affiliate Program; and/or (iii) have been obtained by misleading conducts and/or through collusion and/or manipulation of CryptoTheorem’s services, system, bonuses and/or promotions (including without limitation, via offers to share the Fees directly or indirectly with Leads, and any other unauthorized use of any third party accounts, copyrights or trademarks, in each case, regardless of whether or not it actually causes harm to CryptoTheorem.

1.23. “Second Tier Affiliate” means any Eligible Affiliate identified in CryptoTheorem’s computerized systems as an Eligible Affiliate which has been firstly introduced to CryptoTheorem by the Affiliate (i.e., which did not have any prior connection with CryptoTheorem prior to the introduction by the Affiliate). The identification of an Eligible Affiliate as a Second Tier Affiliate of an Affiliate shall be solely and exclusively determined by CryptoTheorem which determination shall be final and binding upon the Affiliate. Upon CryptoTheorem’s request, the Affiliate shall provide CryptoTheorem with any information and/or documentation with respect to the Second Tier Affiliate.

1.24 “Spread Revenues” means, with respect to any calendar month, the PIP spread that is profited by CryptoTheorem from the real trading activities of the Customers using the Platform, during such month.

1.25. “Territory” means any country, excluding the United States of America (residents and citizens, including its incorporated and unincorporated territories), Belgium, Netherlands, Canada (including Quebec & Ontario), the Republic of Turkey, Japan, Brazil, the Islamic Republic of Iran, Democratic People's Republic of Korea (DPRK), Cuba, Sudan, or Syria, as well as any additional country specifically excluded by CryptoTheorem from time to time at its sole discretion.

1.26. “Platforms” means any trading platform(s) offered by CryptoTheorem to end-users for the purpose of conducting trading activities via the Internet, including any updates and upgrades to such platforms.

1.27. “Transaction Expenses” means, with respect to any calendar month, all the used bonuses provided by CryptoTheorem to the Customers, all chargebacks made with regard to the Customers’ payments and any transaction costs (such as payments processing fees, hedging costs and other payments to third parties) incurred by CryptoTheorem during such month with respect to the trading activities of the Customers.

2 The Engagement

During the term of this Agreement, the Affiliate undertakes to use its best efforts to actively and effectively market and promote the Platform through the Affiliate Websites and/or other referral platforms. In no event shall the Affiliate engage in any marketing or promotional activity related to the Platforms in any area, location, territory or jurisdiction outside of the Territory.

2.2. Subject to the terms and conditions of this Agreement, CryptoTheorem hereby grants the License to the Affiliate and the Affiliate hereby obtains the License from CryptoTheorem, such License shall be valid for the term of this Agreement. It is agreed that the Customers’ registration process and approach to the Platform shall be made solely through CryptoTheorem Websites. The rights granted to the Affiliate hereunder by CryptoTheorem are not exclusive in any manner, and nothing herein shall limit, prevent or preclude CryptoTheorem from entering into other affiliate agreements or other agreements with other third parties and/or from granting rights and/or licenses with respect to the Trading Platform to any other third party. Nothing herein shall prevent CryptoTheorem from promoting and/or marketing its services and/or the Platform by itself.

2.3. Subject to the terms and conditions of this Agreement, CryptoTheorem hereby grants to the Affiliate and the Affiliate hereby obtains from CryptoTheorem a royalty-free, nonexclusive, personal, nontransferable, non-assignable and non-sub-licensable license for the term of this Agreement, to display the CryptoTheorem Brands in the Affiliate Websites solely for the purpose of promoting and marketing CryptoTheorem’s services and/or the Trading Platform. The Affiliate acknowledges and agrees that: (a) it will use the CryptoTheorem Brands only as permitted hereunder; (b) it will use the CryptoTheorem Brands in a lawful manner and in strict compliance with all format(s), guidelines, standards and other requirements prescribed by CryptoTheorem; (c) the CryptoTheorem Brands are and shall remain the sole property of CryptoTheorem; (d) nothing in this Agreement shall confer in the Affiliate any right of ownership in the CryptoTheorem Brands and all use thereof by the Affiliate shall inure to the benefit of CryptoTheorem; and (e) the Affiliate shall not, now or in the future, attempt to register any CryptoTheorem Brand and/or domain name and/or contest the validity of any CryptoTheorem Brands or use any term or mark confusingly similar to any CryptoTheorem Brands.

2.4. It is hereby agreed and clarified that the Affiliate shall not be permitted to market the Platform on any Internet website on which CryptoTheorem promotes the Platform and/or in any other manner which results in the Affiliate competing with CryptoTheorem in relation to the promotion of the Platform. In addition, the Affiliate shall not carry out search engine marketing of the Platform using the word "CryptoTheorem". In the event that the Affiliate is in breach of the foregoing provisions, CryptoTheorem reserves the right to immediately terminate the Agreement pursuant to the terms specified in section 6 below.

2.5. CryptoTheorem shall have the sole and absolute discretion in connection with the rejection or refusal of any Customer to register to and/or trade on the Platform.

2.6. Any and all rights not granted under this Agreement to the Affiliate in the Platform (if any) are expressly reserved by CryptoTheorem.

2.7. CryptoTheorem reserves the right to take legal actions against the Affiliate in the event the Affiliate shall attempt to manipulate CryptoTheorem and/or the Platform and/or abuse CryptoTheorem’s Affiliate Program. Without limitation of the foregoing, CryptoTheorem reserves the right to withhold, setoff and/or deduct from any payment due to Affiliate hereunder in the event of such manipulation and/or abuse and may also terminate this Agreement with immediate effect.

3 Representations and Warranties

3.1. The Affiliate hereby represents, warrants, covenants and agrees to CryptoTheorem as follows:

3.1.1. The Affiliate has full right, power and authority to enter into this Agreement and there is no impediment which would inhibit its ability to perform the terms and conditions imposed on it by this Agreement;

3.1.2. To the extent that the Affiliate is a corporation, that it is a corporation duly organized and validly existing and in good standing and is duly qualified and authorized to do business wherever the nature of its activities or properties requires such qualification or authorization;

3.1.3. No registration with or approval of any government agency or commission is necessary for the execution, delivery or performance by the Affiliate of any of the terms of this Agreement, or for the validity and enforceability hereof or with respect to the obligations of the Affiliate hereunder, except such registrations and approvals that have been made or obtained;

3.1.4. There is no action or proceedings pending against the Affiliate or any of its officers or directors in their capacities as officers and directors of the Affiliate before any court, administrative agency or other tribunal which might have a material adverse effect on its or CryptoTheorem’s business or condition, financial or otherwise, or its operation. No director, officer, key employee or member of the Affiliate’s senior management has a criminal record or criminal prosecution and/or investigation pending;

3.1.5. Neither the execution nor the delivery of this Agreement nor the fulfillment of or compliance with the terms and provisions hereof by the Affiliate shall contravene any provision of law including, without limitation, any statute, rule regulation, judgment, decree, order, franchise or permit applicable to the Affiliate;

3.1.6. The Affiliate’s fulfillment of its responsibilities under this Agreement shall be in strict compliance with the terms and conditions set forth herein;

3.1.7. It is permitted to market the Platform solely in accordance with the express terms of this Agreement and subject to any other terms and conditions instituted by CryptoTheorem from time to time during the term hereof;

3.1.8. It shall comply with any applicable data protection and privacy requirements and any analogous legislation in any and all jurisdictions applicable to the Customers/Leads. The Affiliate shall also provide to CryptoTheorem upon demand, all information and documentation required by any Organization for Economic Co-operation and Development or an equivalent anti-money laundering authority directives in relation to the Affiliate, and if applicable, its directors, officers, key employees, senior management and beneficial owners;

3.1.9. It is, and it shall remain during the term of this Agreement, in full compliance with the laws and regulations applicable within each territory in which it shall market and promote the Trading Platforms. The Affiliate agrees to cease its marketing activities and/or cease the operation of the same in any territory requested by CryptoTheorem upon the occurrence of any illegality or suspicion of illegality; and

3.1.10. It shall: (i) market and promote the Platform solely to Customers/Leads of legal age of majority, (ii) require sufficient proof of Leads/Customers’ identities where and when appropriate, and (iii) ensure that its promotions and related materials are in no way offensive, indecent, objectionable or obscene.

3.2. CryptoTheorem hereby represents and warrants to the Affiliate as follows:

3.2.1. It is duly organized and validly existing under the laws of the state of its incorporation and has full corporate power and authority to enter into this Agreement and to carry out the provisions hereof;

3.2.2. It is duly authorized to execute and deliver this Agreement and to perform its obligations hereunder;

3.2.3. This Agreement is a legal and valid obligation binding upon it and is enforceable in accordance with its terms. The execution, delivery and performance of this Agreement by CryptoTheorem does not conflict with any agreement, instrument or understanding, oral or written, to which it is a party or by which it may be bound, nor violate any law or regulation of any court, governmental body or administrative or other agency having authority over it;

3.2.4. CryptoTheorem is a lawful owner/lawful licensee of the Intellectual Property Rights in the Trading Platform and in the CryptoTheorem Brands.

4 Obligations and Responsibilities of the Affiliate

4.1. The Affiliate undertakes that its marketing activity and/or any content to be posted and/or published in the Affiliate’s Websites shall not be directed toward minors and/or engage in any other practices which may affect adversely the high image, credibility or reputation of CryptoTheorem, its services and/or its Platforms, including without limitation of the generality of the foregoing, promoting sexually explicit materials promotes, violence, discrimination based on race, sex, religion, nationality, disability, sexual orientation or age and/or any illegal activities or otherwise reasonably objectionable content, include material that is in breach of and/or infringes any Intellectual Property Rights of any third party (including any material copied from third parties without their permission) and/or including any false, misleading or disparaging representations or statements with respect to the Platform and/or CryptoTheorem.

4.2. The Affiliate shall not publish any material which refers to the Platform, CryptoTheorem Brands or any other name or mark owned by CryptoTheorem unless such publication is in compliance with CryptoTheorem’s guidelines. Upon request by CryptoTheorem, the Affiliate shall immediately remove any publication referring to the Trading Platform, CryptoTheorem Brands or any other name or mark owned by CryptoTheorem.

4.3. The Affiliate shall not copy any content from CryptoTheorem’s Websites and/or publications and shall not post in any website and/or elsewhere, any material published in CryptoTheorem’s Websites and/or publications. The Affiliate shall not copy any content from any other Affiliate’s websites.

4.4. The Links shall clearly display CryptoTheorem’s official logo pursuant to the provisions of this Agreement. The Affiliate shall not be permitted to change CryptoTheorem’s logos and/or banners and/or images and/or to make any use of them beyond the uses permitted hereunder. CryptoTheorem reserves the right to modify at any time its official logo and/or CryptoTheorem Brands and/or any other marketing materials, and the Affiliate agrees to modify CryptoTheorem’s logo accordingly within 8 days of notice given by CryptoTheorem to the Affiliate regarding such variation (such notice shall be posted in the Affiliate’s account maintained at cryptotheorem.com).

4.5. The Affiliate undertakes, with respect of any marketing and/or promotional activity involving “Pay Per Click” (“PPC“) and/or “Search Engine Marketing” (“SEM“), as follows:

4.5.1. Not to use the CryptoTheorem Brands in any way or manner whatsoever, including but not limited to the words “CryptoTheorem” and/or “CryptoTheorem USA” spelled in any possible way (including with typos, spaces, signs, symbols or in any other way). Such forbidden use of the CryptoTheorem Brands includes the use of such words/trademarks in the Affiliate’s advertisements or in any part therewith, in the displayed URL and/or in the destination URL;

4.5.2. Not to bid on the CryptoTheorem Brands, including but not limited to the words “CryptoTheorem” and/or “CryptoTheorem USA” spelled in any possible way (including with typos, spaces, signs, symbols or in any other way);

4.5.3. To use Affiliate Websites for all PPC and/or SEM campaigns. The Affiliate’s advertisements and/or any part therewith shall not lead or redirect potential clients directly to CryptoTheorem Websites. The Affiliate is allowed to use the landing page provided by CryptoTheorem on Affiliate Websites ONLY, but in no way shall the Affiliate use any URL containing the words “CryptoTheorem” and/or “CryptoTheorem USA”;

4.5.4. Not to use CryptoTheorem Brands’ Top Level Domains as landing pages and/or use CryptoTheorem’s and/or CryptoTheorem USA’s landing URL’s and/or use CryptoTheorem’s and/or CryptoTheorem USA’s displayed URL’s.

4.6. In no event shall the Affiliate engage in any e-mail marketing or promotion with respect to the Platform and/or CryptoTheorem, except as expressly set forth in this Agreement. In the event that the Affiliate has an Opt-in List, the Affiliate may make a written request to CryptoTheorem to send e-mails regarding the offering of the Trading Platform to the individuals on the Opt-in List. In the event that CryptoTheorem approves such request in writing, the Affiliate shall comply with any and all applicable laws, rules, regulations and directives, including but not limited to those relating to e-mail marketing and “spamming”. Without limiting the generality of the foregoing, the Affiliate: (a) shall not send any e-mail regarding the Platform, CryptoTheorem to any individual or entity that has not requested such information, and (b) shall always include “unsubscribe” information at the top and bottom of any e-mail regarding the Platform, CryptoTheorem.

4.7. In addition to the restrictions set forth in sections 4.5 and 4.6 above, the Affiliate shall not: (a) engage in any fax, broadcast or telemarketing and/or any other offline marketing methods with respect to the Platform and/or CryptoTheorem, (b) use Malware and/or Spyware techniques and/or Peer to Peer (P2P) distribution methods and/or Paid to Click (PTC) networks and/or doorway pages opening CryptoTheorem Websites inside an iframe and/or use any other aggressive advertising or marketing methods in any of its dealings relating to the Platform, CryptoTheorem.

4.8. CryptoTheorem may provide the Affiliate with copies of or access to the creative material which CryptoTheorem shall make available to its business partners, such creative material shall bear solely CryptoTheorem Brands. The creative material shall be accessible from CryptoTheorem partner program website (cryptotheorem.com). The creative materials shall be provided “as is” AND WITHOUT WARRANTY of any kind. From time to time, CryptoTheorem may customize material to adhere to any regulatory requirements in the territories in which it operates. The Affiliate may not amend and/or customize CryptoTheorem’s creative material and shall display CryptoTheorem’s creative material on the Affiliate Websites/other referral platforms solely for the purpose of marketing and promoting CryptoTheorem’s services and/or the Platform.

4.9. The Affiliate shall be solely responsible to any matter related to the Affiliate Websites, including with respect to the technical operation thereof and to the accuracy of the information and materials posted therein. The Affiliate undertakes that the Affiliate Websites shall not look like and/or create the impression that they are CryptoTheorem’s Websites and that such Affiliate Websites shall not contain and/or display any information and/or materials of CryptoTheorem and/or the CryptoTheorem Brands unless the content of such information and/or materials and/or the manner in which they are displayed are in compliance with the guidelines of CryptoTheorem. In the event that CryptoTheorem shall require the Affiliate to remove from the Affiliate Websites and/or any other marketing media used by the Affiliate any content related to CryptoTheorem, the Affiliate shall immediately comply with such request and shall remove such content within not later than 24 hours from CryptoTheorem's request. The Affiliate further undertakes not to use any domain names similar to the domain names used by CryptoTheorem including any domain containing any of the CryptoTheorem Brands.

4.10. CryptoTheorem does not assume any responsibility towards the Affiliate and/or any third party acting on such information contained in the Affiliate Websites and/or CryptoTheorem Websites and/or Platform as to the accuracy or delay of information such as quotations, news, and charts derived from quotations.

4.11. The Affiliate shall be responsible to provide the Customers with all the services to be agreed between the Affiliate and the Customers and CryptoTheorem shall not bear any responsibility in such respect.

4.12. The Affiliate undertakes to cooperate with CryptoTheorem regarding any copyright, trade mark, branding and/or domain name that appears on the Affiliate Website and/or other referral platforms and/or the Platform.

4.13. The Affiliate shall, except as otherwise set forth in this Agreement, bear all costs and expenses incurred in connection with its marketing activity, including advertising, marketing and promotion of trading on the Affiliate Websites and/or referral platforms and/or the Platform as well as all other related operational costs.

4.14. The Affiliate shall be responsible and liable for obtaining and maintaining of, as well as for compliance with, any and all applicable laws and regulations as may be necessary for the Affiliate’s performance of its undertakings under this Agreement, including applicable trading laws. CryptoTheorem shall under no circumstances be held liable for and the Affiliate shall indemnify CryptoTheorem against any and all claims asserted against CryptoTheorem by reason of the Affiliate’s and/or its business partners’ advertising, marketing and promotional activities and efforts.

4.15. The Affiliate hereby releases CryptoTheorem from any and all responsibilities for the accuracy or reliability or correctness of the information (including feeds, whether provided by CryptoTheorem or by any other party) presented to Leads/Customers through the Platform. The Affiliate further acknowledges that it is aware that the information presented to Leads/Customers through the Platform shall not infer a recommendation to enter into or refrain from entering into specific trading.

4.16. The Affiliate shall promptly inform CryptoTheorem of any information known to the Affiliate related to any Leads that may reasonably lead to a claim, demand or liability of or against CryptoTheorem by any third party.

4.17. The Affiliate agrees to indemnify, defend and hold harmless CryptoTheorem and its directors, officers, employees, subcontractors and agents thereof with respect to any claim, demand, cause of action, debt or liability, including reasonable attorneys’ fees, to the extent that the same are based upon or arises out of: (a) the Affiliate’s breach of any representation, warranty, obligation or covenant under this Agreement; (b) any warranty, condition, representation, indemnity or guarantee relating to CryptoTheorem granted by the Affiliate to any Lead or other third party. In the event: (a) that the Affiliate markets or promotes CryptoTheorem and/or the Platform to any person or entity outside of the Territory; or (b) of any breach or threatened breach of any provision of Sections 4 and/or 7 hereunder, then in addition to all other rights and remedies available to CryptoTheorem under this Agreement and under applicable law, CryptoTheorem shall have the right to: (i) immediately enjoin all such activity, without the necessity of showing damages or posting bond or other security, (ii) receive a prompt refund of all amounts previously paid to the Affiliate hereunder, and (iii) be indemnified for any losses, damages or liability incurred by CryptoTheorem in connection with such violation

5 Fees and Payments

5.1 During the term of this Agreement, and subject to the Affiliate’s fulfillment of its obligations hereunder, CryptoTheorem shall pay the Affiliate, for each calendar day, the Fees of the type and in the amount set forth in the Affiliate’s account maintained at cryptotheorem.com and/or in any other location in CryptoTheorem's systems (the “Fees“). All payments hereunder and/or pursuant to any other arrangement between the Affiliate and CryptoTheorem are subject to risk analysis considerations and anti-money laundering procedures. CryptoTheorem reserves the right to demand and receive information about any Lead and to assess the competency of such Lead for payments.

5.2. IN ADDITION TO ANY OTHER TERMS AND CONDITIONS SET FORTH ANYWHERE IN THIS AGREEMENT OR UNDER APPLICABLE LAW, AFFILIATE SHALL NOT BE ENTITLED TO RECEIVE ANY FEES FOR ANY CUSTOMER/FTD/LEAD AND/OR ANY OTHER TYPE OF TRAFFIC ENTITLING THE AFFILIATE FOR PAYMENT UNLESS AND UNTIL THE FOREGOING HAS BEEN APPROVED AND QUALIFIED BY CRYPTOTHEOREM. FOR THE REMOVAL OF ANY DOUBT IT IS HEREBY CLARIFIED THAT CRYPTOTHEOREM RESERVES THE RIGHT, AT ITS SOLE AND ABSOLUTE DISCRETION, TO CHANGE, MODIFY, ADD OR REMOVE, AT ANY TIME, ANY CRITERIA APPLYING TO ANY OF THE COMPENSATION PLANS, INCLUDING WITHOUT LIMITATION, SETTING ANY BASELINE, THRESHOLD, MINIMUM DEPOSITS/EARNINGS AND/OR OTHER REQUIREMENT(S) FOR QUALIFYING INTO ANY OF THE COMPENSATION PLANS AND/OR FOR RECEIVING ANY FEES SET FORTH HEREIN.

5.3. For avoidance of doubt and without derogating from the generality of the foregoing, the Affiliate shall not be entitled to receive the Fees and/or any other payment (pursuant to any arrangement between the Affiliate and CryptoTheorem) in the following circumstances:

5.3.1. the Affiliate is not an Eligible Affiliate;

5.3.2. the Revenues were generated from traders that have been solicited outside the Territory;

5.3.3. the Revenues were generated from accounts that CryptoTheorem has a reason to believe are owned and/or managed by the Affiliate and/or any of its shareholders and/or officers and/or any of their family members and/or dependents and/or relatives, without explicit written approval of CryptoTheorem;

5.4 Holdover

5.4.1 Holdover for Non-Compliance. CryptoTheorem may, at its sole and exclusive discretion, withhold, delay or deny payment of the Fees in any of the following events: (i) CryptoTheorem has reason to believe that the Affiliate's activity is not in compliance with any applicable law, including, without limitation to, the CySEC Rules, FCA Rules and/or any other applicable regulator; (ii) the Company has reason to believe that the Affiliate's activity is in breach of this Agreement; (iii) the Affiliate has failed to complete any form as may be required by CryptoTheorem or has completed misleading or incorrect information in a form provided by Affiliate to CryptoTheorem; (iv) the Affiliate has failed to provide any document as may be demanded by CryptoTheorem; and/or (v) CryptoTheorem has been notified by any third party of the alleged infringement of property or rights (e.g. intellectual property rights) by the Affiliate or by the Affiliate's activity. Affiliate hereby irrevocably waives any claim or demand against the Company, its directors, officers, shareholders, employees in respect of such action taken by CryptoTheorem.

5.4.2. Holdover for Non-Qualified Traffic. CryptoTheorem may, at its sole and exclusive discretion, withhold, delay or deny payment of the Fees if CryptoTheorem has a reason to believe that there is a Non-Qualified Traffic in the Affiliate account for up to one hundred and eighty (180) days in order to verify the relevant transactions. In the event that CryptoTheorem determines the activity constitutes Non-Qualified Traffic, CryptoTheorem shall recalculate or withhold the Fees accordingly and in its sole discretion. It is hereby further clarified that in any event that CryptoTheorem determines that the suspected transactions are in fact Non-Qualified Traffic, CryptoTheorem shall have the right, in addition to any other right or remedy available to it under this Agreement or applicable law, to render the Link assigned to such Affiliate inoperative, to change the Affiliate’s compensation plan (including retroactively with respect to the Non-Qualifed Traffic) and immediately block Affiliate's access to CryptoTheorem’s Affiliate Program, with no compensation to Affiliate. Affiliate hereby irrevocably waives any claim or demand against CryptoTheorem, its affiliates, its directors, officers, shareholders, employees in respect of such action taken by CryptoTheorem.

5.5. Acceptance of Fees or acceptance of other payment by Affiliate will be deemed full and final settlement of Affiliate Fee due for the calendar month indicated. Hence, if Affiliate disagrees with the Reports or amount payable, Affiliate should NOT accept payment for such amount and immediately send CryptoTheorem a written notice of its dispute. dispute notices must be received by CryptoTheorem within three (3) days of the end of each calendar day for which payment is made, or Affiliate's right to dispute such report or payment will be deemed waived and Affiliate shall have no claims in such regard.

5.6. Inactive Affiliate. Without derogating from the foregoing, it is agreed that in the event that the Affiliate shall not provide at least three (3) FTDs, during each period of three (3) months throughout the term of this Agreement, then in such event the Affiliate shall no longer be entitled to receive the Fees and/or any other payments from CryptoTheorem. For the avoidance of doubt, it is clarified and agreed that in such circumstances, following the lapse of such 3-months period the Affiliate shall not be entitled to receive the Fees and/or any other payment hereunder, including any payment with respect to any Customer for which the Affiliate was entitled to receive Fees prior to such time. In addition to the foregoing, CryptoTheorem may, under its sole discretion, upon the lapse of such 3-months period, either terminate under Section 6 below or change the compensation plan of the Affiliate (reduce any percentage or amount payable thereunder). In such event, effective as of the date of CryptoTheorem’s notification to the Affiliate regarding the change of the compensation plan, the Affiliate shall be compensated under the new compensation plan and it shall not be entitled to receive any payment under the previous compensation plan.

5.7. In the event that: (a) any Click has not become a Lead within a period of 60 days from the effective date of the Click; or (b) any Lead has not become an FTD within a specified period to be determined by CryptoTheorem in its sole discretion, CryptoTheorem reserves the right to either: (i) deduct from any Fees payable to the Affiliate the reasonable re-acquisition cost incurred by CryptoTheorem as shall be determined by CryptoTheorem; or (ii) remove such Lead from the Affiliate’s Leads list, in which case no further payment shall be made to the Affiliate with respect to such Lead.

5.8. It is emphasized that the calculation of the Fees shall be made on a monthly basis and that the Net Revenues shall be calculated separately for each calendar month. Notwithstanding, in the event that the Net Revenues are negative in any calendar month (i.e., the Transaction Expenses are greater than the Revenues), then the negative balance (i.e. the negative Net Revenues) shall be carried forward to the next calendar months and shall be deducted from the Net Revenues in such months for the purpose of calculating the Fees hereunder.

5.9. The measurements and calculations of the Net Revenue made available to the Affiliate through the Affiliate's account maintained at cryptotheorem.com (as such calculations may be amended and/or updated by CryptoTheorem from time to time) are conclusive and the Affiliate shall not have the right to appeal and/or disagree with respect thereto. In order to ensure accurate tracking and calculation of the Net Revenue, the Affiliate must ensure that the Link is properly formatted.

5.10. It is agreed that the Affiliate may not receive any payment from CryptoTheorem and/or withdraw payments from its accounts with CryptoTheorem in the event that the Affiliate has not completed the verification requirements of CryptoTheorem, including the provision of the identification information and/or documents required by CryptoTheorem, as amended and/or updated from time to time. It is further agreed that no payment hereunder shall be made to any entity other than the Affiliate and/or to any account and/or payment method not registered in the name of the Affiliate and/or to any account and/or payment method the details of which are not identical to those provided to CryptoTheorem by the Affiliate.

5.11. The Fees shall be deposited into the Account that the Affiliate has opened with the Platform (the "Affiliate Account"), which Affiliate Account is subject to the standard terms and conditions applicable to the trading accounts opened with the Platform. Thereafter, the Fees shall either (i) remain in the Affiliate Account until withdrawn by the Affiliate; or (ii) be automatically transferred to the account and/or payment method that the Affiliate has designated during the registration to the Affiliate Program, which account and/or payment method must be registered in the name of the Affiliate (such account and/or payment method shall be referred to herein as the "Affiliate External Account"). Should the Affiliate choose the second option (automatic transfer of the Fees), the outstanding balance in the Affiliate Account shall be transferred to the Affiliate External Account, on the dates specified below. Notwithstanding, no payment shall be transferred and/or withdrawn (either automatically or otherwise) from the Affiliate Account to the Affiliate External Account and/or any other account, in the event that the Affiliate has not complied with the verification requirements of CryptoTheorem.

5.12. Generally CryptoTheorem shall deposit the Fees into the Affiliate Account within 1 (one) day from the end of the day with respect of which the Fees are payable. In the event that the Affiliate has chosen that the outstanding balance in the Affiliate Account shall be automatically transferred to the Affiliate External Account, such automatic transfer shall be generally made within up to 7 (seven) business days from the date in which the money has been transferred to the Affiliate Account (provided that the Affiliate is in compliance with the verification requirements of CryptoTheorem at the time of payment). In the event that the Affiliate did not choose the automatic transfer option, the outstanding balance in the Affiliate Account shall be available for withdrawal within not later than 7 (seven) business days from the date in which the money has been transferred to the Affiliate Account (provided that the Affiliate is in compliance with the verification requirements of CryptoTheorem at the time of payment). Notwithstanding, in the event that the Fees in any calendar day shall be less than US$100, or US$500 if the Fees are payable by wire transfer, then such Fees shall not be payable on such dates and shall be carried forward to the next month in which the aggregate Fees not paid yet shall reach such threshold.

5.13. CryptoTheorem reserves the right to modify the Fees’ structure and/or the payment terms thereof, including, without derogation to the generality of the foregoing, changing the Fees from and/or to Cost Per Acquisition, Cost Per Click or payments calculated as percentage from the Net Revenues, at any time, upon written notice to be sent to the Affiliate via e-mail and/or posted on CryptoTheorem’s Websites including in the Affiliate’s account maintained at cryptotheorem.com. It is agreed that any access of the Affiliate to CryptoTheorem’s Websites following such modification and/or receipt of payment calculated pursuant to such modified terms (the earlier to occur of the two) shall constitute the Affiliate’s agreement, acceptance and consent for such modification. It is further agreed that CryptoTheorem may, under its sole discretion, retroactively change the compensation plan of the Affiliate, in the event that CryptoTheorem has a reasonable suspect of a manipulation of CryptoTheorem and/or the Trading Platform and/or of any abuse of CryptoTheorem’s Affiliate Program and/or of the Affiliate's compensation plan and/or from any other reasonable grounds under CryptoTheorem's sole and absolute discretion. In such event, effective as of the date specified in CryptoTheorem’s notification to the Affiliate regarding the change of the compensation plan, the Affiliate shall be compensated under the new compensation plan and it shall not be entitled to receive any payment under the previous compensation plan (and in the event that any payments have already been made under the previous compensation plan, the Affiliate shall immediately return CryptoTheorem any such payment and CryptoTheorem shall also be permitted to deduct such payments from any future payments due to the Affiliate, which may cause an Affilaite’s account to be in a negative balance).

5.14. Each Party shall be responsible for payment of its respective taxes due under any applicable law. CryptoTheorem shall make deductions from any payment made to the Affiliate under this Agreement as may be and to the extent required under any applicable law, unless the Affiliate provides CryptoTheorem with appropriate tax exemption documents.

6 Term and Termination

This Agreement shall be in effect for undefined period of time commencing on the date in which the Affiliate executed the Registration Form.

6.2. This Agreement may be terminated with immediate effect by either party, with or without cause, by providing the other party with termination notice. For the avoidance of doubt, and without derogating from the generality of the foregoing, it is clarified that CryptoTheorem shall be permitted to terminate this Agreement with immediate effect upon any breach of this Agreement by the Affiliate without having to provide the Affiliate with the opportunity to rectify such breach.

6.3. Upon termination of this Agreement for whatever reason: (a) each party shall forthwith return to the other party all property of the other party in its possession or control (including all documentation, creative materials and all Confidential Information), including any copies and derivations thereof. In addition, the Affiliate shall destroy all of the foregoing (in the case of a software by erasing it from the magnetic media on which it is stored) and certify in writing to CryptoTheorem that they have been destroyed; (b) the Affiliate shall immediately cease to market and/or promote the Platform in any manner, shall cease to use any of CryptoTheorem’s Intellectual Property Rights, trade secrets and technical know-how and shall immediately cease displaying any CryptoTheorem Brands and/or other CryptoTheorem’s material on any website or otherwise; and (c) all rights granted to the Affiliate hereunder will immediately cease; provided, however, that the Affiliate shall be entitled to receive the Fees pursuant to terms and conditions of this Agreement, during the three (3) months period immediately following the effective date of termination of this Agreement. Notwithstanding, in the event that the Agreement shall be terminated by CryptoTheorem due to any breach of the Agreement by the Affiliate, then following such termination the Affiliate shall not be entitled to receive the Fees and/or any other payment hereunder, including any payment with respect to any Customer for which the Affiliate was entitled to receive Fees prior to such time and including any payments already accrued in favor of the Affiliate prior to such time and not yet paid to the Affiliate.

6.4. In the event that such termination shall be made by CryptoTheorem due to any breach of this Agreement by the Affiliate, then such termination shall be without prejudice to any other remedy to which CryptoTheorem may be entitled under any applicable law and/or this Agreement. In the event of termination or expiration of this Agreement for any reason whatsoever, no sums or other form of compensation shall be due to the Affiliate from CryptoTheorem by reason of goodwill, loss of future profits, reimbursed investment, severance, or any concept or in the nature of a termination indemnity. Termination of this Agreement for any cause shall not release either party from any liability which at the time of termination has already accrued to the other party or which thereafter may accrue in respect of any act or omission prior to termination or from any obligation which is expressly stated herein to survive termination. Any provision of this Agreement which should survive and/or may be reasonably interpreted as surviving the termination of the Agreement, including the provisions of sections 2.2, 2.3, 7, 8, 9 and 10 to this Agreement, shall survive the termination of the Agreement.

7 Intellectual Property and Confidentiality

7.1 As between CryptoTheorem and the Affiliate, the Platform, CryptoTheorem Brands, the creative materials of CryptoTheorem, all demographic and other information relating to any Lead and/or Customer (including Lead/Customer Data), and all software, documentation, hardware, equipment, devices, templates, tools, documents, processes, methodologies, know-how, websites, and any additional intellectual or other property used by or on behalf of CryptoTheorem or otherwise related to the Platform, together with all copyrights, trademarks, patents, trade secrets and any other proprietary rights inherent therein and appurtenant thereto (collectively, the “CryptoTheorem’s Property“), are and shall remain the sole and exclusive property of CryptoTheorem and CryptoTheorem shall retain all rights, title and interest in and to CryptoTheorem’s Property and all Intellectual Property Rights derived therefrom (including all derivations and modifications made thereto). To the extent that the ownership of any of CryptoTheorem’s Property does not automatically vest in CryptoTheorem by virtue of this Agreement, or otherwise, the Affiliate hereby transfers and assigns to CryptoTheorem, upon the creation thereof, all rights, title and interest the Affiliate may have in and/or to such CryptoTheorem’s Property, including the right to sue and recover for past, present and future violations thereof.

7.2. Without derogating from the generality of any provision of this Agreement, it is hereby clarified that CryptoTheorem shall be permitted, both during the term of this Agreement and/or following the termination and/or expiration of the Agreement, to use, any information related to the Leads and/or Customers (including the Leads/Customer Data), and to provide any services to the Lead/Customers, and that the Affiliate shall not have claim and/or right with respect thereto, other than the right to receive the Fees pursuant to the terms of this Agreement. It is further clarified that the Lead/Customer Data shall be deemed as CryptoTheorem’s sole and exclusive proprietary information and property and shall be deemed as CryptoTheorem’s Confidential Information.

7.3. Under no circumstances during the Term hereof and thereafter shall the Affiliate assert or contest any ownership rights in and to the Platform and/or CryptoTheorem Brands and/or CryptoTheorem’s Property and/or the Intellectual Property Rights derived therefrom in any action or proceeding of whatever kind or nature, nor shall the Affiliate take any action that may prejudice or adversely affect CryptoTheorem’s rights in the Platform and/or CryptoTheorem Brands and/or CryptoTheorem’s Property and/or the Intellectual Property Rights therein (including any registration of CryptoTheorem Brands in the name of the Affiliate). The Affiliate may not do anything to render such Intellectual Property Rights generic, weaken its validity or diminish its associated goodwill. Upon termination of this Agreement, all of the rights granted to the Affiliate hereunder shall terminate and all rights shall revert to CryptoTheorem without the taking of any action on the part of either party.

7.4. The Affiliate shall maintain suitable copyright and trademark notices throughout the Affiliate Websites (such notices shall also appear on the other referral platforms) that shall conform in all respects to CryptoTheorem’s copyright and trademark requirements. CryptoTheorem may include some or all of the Affiliate Trademarks in its own marketing and promotional materials.

7.5. The parties hereby acknowledge and agree that from time to time before, during and after the Term hereof, either party may have access to or become acquainted with the Confidential Information of the other party. Both the Affiliate and CryptoTheorem shall use their best efforts to protect each other’s Confidential Information from improper disclosure and will not, during or after the Term of this Agreement or thereafter, directly or indirectly, use or disclose any such Confidential Information to any person, firm or corporation for any reason or purpose whatsoever, nor shall either party, for itself or in any representative or other capacity, utilize any such Confidential Information in any manner for its own account or the account of others, except in connection with its performance under this Agreement.

7.6. CryptoTheorem shall have the right to mention the existence of this Agreement (but not its terms) in its respective marketing materials, public announcements or as a reference for future customers. This right is given on the condition that: (i) any such marketing materials accurately reflect the nature of the business relationship created by this Agreement, and (ii) any such marketing materials do not disclose any of the Affiliate’s Confidential Information pursuant to the terms set forth in this Article 7. Any press releases or public statements regarding this Agreement by the Affiliate shall require the consent of CryptoTheorem as to content and release date, which shall not be unreasonably withheld or delayed.

8 Disclaimer of Warranty and Limitation of Liability

8.1. Except as expressly set forth above and to the maximum extent permitted by applicable law, CryptoTheorem makes no warranty of any kind, express, implied or statutory, regarding the Trading Platform, and all such warranties, including, without limitation, the implied warranties of merchantability and/or fitness for a particular purpose are hereby expressly disclaimed by CryptoTheorem. The Affiliate acknowledges that CryptoTheorem has not represented or warranted that the Trading Platform will be uninterrupted, error free, without delay or without compromise of the security systems and features therein and appurtenant thereto. No representations or warranties of any kind are made by CryptoTheorem with regards to any services provided by any wireless carrier or authorized distributor.

8.2. Under no circumstances shall CryptoTheorem (or any of its shareholders, directors, officers, employees, Affiliates, representatives or licensors) be liable to the Affiliate for any consequential, incidental or special damages (including damages for business interruption, loss of business information and the like) arising out of or in connection with this Agreement, including with respect to the use or inability to use the Platform, even if CryptoTheorem has been advised of the possibility of such damages. To the extent that in a particular circumstance any disclaimer or limitation on damages, losses or liability set forth herein (whether direct, indirect, consequential, incidental or special) is prohibited by applicable law, then, instead of the provisions hereof in such particular circumstance, CryptoTheorem (and its shareholders, directors, officers, employees, Affiliates and representatives) shall be entitled to the maximum disclaimers and/or limitations on damages and liability available at law or in equity by such applicable law in such particular circumstance.

8.3. Without derogating from the above, if CryptoTheorem is found liable (whether under contract, tort (including negligence) or otherwise), the cumulative liability of CryptoTheorem for all claims whatsoever related to the Trading Platform or otherwise arising out of this Agreement, shall not exceed the payments made to the Affiliate by CryptoTheorem under this Agreement during the six (6) months preceding the event that gave rise to the action or claim.

8.4. No action, whether based in contract, strict liability or tort, including any action based on negligence, arising out of the performance of this Agreement, may be brought by the Affiliate against CryptoTheorem more than twelve (12) months after such cause of action accrued

9 Affiliate Network

9.1 The provisions of this section 9 shall apply solely with respect to any Affiliate that is an Affiliate Network.

9.2. The Affiliate undertakes to provide CryptoTheorem, in advance, with the contact details of all the entities that shall refer potential customers to the Platform through the Affiliate Websites and/or other means of referral (the “Sub-Affiliates”) and their respective Affiliate Websites, in order to enable CryptoTheorem to audit the compliance of the Sub-Affiliates with the terms and conditions of this Agreement and/or with the branding guidelines of CryptoTheorem. The Affiliate also undertakes to provide CryptoTheorem with full details and information with respect to the websites of the SubAffiliates. It is further agreed that any marketing campaign, including the type of the campaign and the Sub-Affiliate running the campaign, shall be agreed between the Affiliate and CryptoTheorem in advance.

9.3. The Affiliate shall procure and shall be responsible to ensure that all the Sub-Affiliates shall fully comply with all the provisions of this Affiliate Program, including without limitation, the branding guidelines of CryptoTheorem and that a Sub-Affiliate may not appoint any further subaffiliate other than where prior written consent of CryptoTheorem has been received by the Affiliate. The Affiliate shall notify CryptoTheorem immediately of any circumstances indicating that any marketing activity may be occurring, or have occurred, in breach of this Section 9.3. The Affiliate further undertakes to enforce upon the Sub-Affiliates such provisions and/or guidelines and to cause the Sub-Affiliates to comply with any instruction that CryptoTheorem may provide to either of them within not later than 48-hours from CryptoTheorem’s request. To the extent any such Sub-Affiliate shall not comply with any such instructions, CryptoTheorem may, at its sole discretion and in addition to any other remedy available to it, deduct from any amount due to the Affiliate the respective portion of the Fees payable to the Affiliate in respect of such breaching Sub-Affiliate.

9.4. CryptoTheorem shall not be liable for any payments due to the Sub-Affiliates and solely the Affiliate shall be responsible to pay to the Sub-Affiliates all the fees and payments due to them in relation to the referral of potential traders to the Trading Platform and/or otherwise in relation to the engagement between the Affiliate and CryptoTheorem. The Affiliate shall indemnify CryptoTheorem for any claim to be made by the Sub-Affiliates, if any, to receive payments and/or other benefits from CryptoTheorem.

10 Miscellaneous

10.1. This Agreement constitute the entire agreement and supersede all previous communications or agreements, either oral or written, between the parties with respect to the subject matter hereof. In entering into this Agreement, neither party has relied upon any statement, representation, warranty or agreement of the other party except for those expressly contained in this Agreement.

10.2. CryptoTheorem shall be permitted to set-off any amounts owed to it by the Affiliate (including the amount of any compensation which CryptoTheorem shall be entitled to receive from the Affiliate) against any amounts due to the Affiliate by CryptoTheorem hereunder. CryptoTheorem shall also be permitted to set-off any amounts which have been paid to the Affiliate by CryptoTheorem in access (i.e., any overpayment made to the Affiliate) against any amounts due to the Affiliate by CryptoTheorem hereunder.

10.3. CryptoTheorem shall have the right, at any time and under its sole and absolute discretion, to change and/or amend the terms and conditions of this Agreement. The Affiliate agrees that any new format of this Agreement which shall be posted on CryptoTheorem’s Websites shall be considered as sufficient provision of notice for the changes and/or amendments made in such new format and shall become effective as of the date of posting it as aforesaid.

10.4. Section headings are provided solely for reference purposes and in no way define, limit, interpret or describe the scope or extent of such section or in any way affect this Agreement.

10.5. Neither party shall be liable to the other for any delay or failure to perform its obligations under this Agreement if such delay or failure arises from a cause beyond the reasonable control of and is not the fault of such party, including but not limited to labor disputes, strikes, industrial disturbances, acts of God, acts of terrorism, floods, lightening, utility or communication failures, earthquakes or other casualty. If a force majeure event occurs, the non-performing party is excused from whatever performance is prevented by the force majeure event to the extent prevented.

10.6. This Agreement shall exclusively be governed by and construed in accordance with the laws of the … with the exception of its conflict of laws. The parties shall use all reasonable efforts to amicably resolve any dispute or controversy arising directly out of this Agreement. In the event of a dispute which cannot be resolved by the between the parties, themselves, either party may commence a binding arbitration proceeding in accordance with the Rules of Arbitration of the International Chamber of Commerce by a single arbitrator to be appointed in accordance with the said Rules. The arbitration shall be conducted in …, unless otherwise agreed by the parties. The language of the arbitration shall be English. It is expressly agreed that the arbitration award shall be final and binding upon the parties. Each party acknowledges that in the event of a breach of this Agreement, a party’s remedies at law may be inadequate, and accordingly each party agrees that in the event of a breach of this Agreement by such party the other party shall have the right to injunctive relief or other appropriate remedies before any competent court to restrain such party from breaching this Agreement.

10.7. No failure by either party to exercise its rights under this Agreement shall be deemed a waiver of any such rights. No term or provision hereof shall be deemed waived or any breach excused, unless such waiver or consent shall be in writing and signed by the party claimed by the other to have waived or consented. No waiver of any breach of this Agreement shall be held to constitute a waiver of any other or subsequent breach.

10.8. If any provision of this Agreement is determined to be invalid or unenforceable, the remaining provisions of this Agreement shall not be affected thereby and shall be binding upon the parties hereto, and shall be enforceable, as though said invalid or unenforceable provision were not contained herein.

10.9. Neither this Agreement nor any of the rights granted hereunder nor any interest herein, may be sold, assigned, conveyed, delegated, subcontracted or otherwise transferred or encumbered by the Affiliate at any time, without CryptoTheorem’s prior written consent, and any attempt to do so will be deemed null and void. CryptoTheorem shall be permitted to assign its rights and/or obligations under this Agreement to any of CryptoTheorem’s Affiliated Corporations. This Agreement shall be binding upon, and shall inure to the benefit of the parties hereto and their respective successors and permitted assigns.

10.10. Any notices given under this Agreement shall be in writing and will be deemed to have been sufficiently given when delivered by hand or sent via facsimile transmission (when acknowledged by the recipient), overnight courier service or by certified or registered mail, to the parties at the addresses set forth above in the preamble or as subsequently changed by notice duly given. Notices shall be effective on the business day sent if delivered personally or via facsimile, on the next business day if sent by overnight courier, or five (5) business days after post-marking if sent by certified or registered airmail. In the event that the Affiliate shall not indicate its correct address in the Registration Form, CryptoTheorem may deliver any notice hereunder to the Affiliate’s e-mail address and such notice shall be effective on the business day in which the e-mail was sent.

Fees

This page describes the various the commission plans available to the Affiliate during the Term. The fees payable under each plan shall be paid in accordance with one of the following plans, as shall be decided by CryptoTheorem in its sole and absolute discretion.

The Affiliate shall only be entitled to receive payments under one of the following plans (as shall be decided by CryptoTheorem) and shall not be eligible for payments under two plans, unless otherwise determined by CryptoTheorem.

All capitalized terms used in this page shall bear the meanings given to them under CryptoTheorem’s Affiliate Program.

First Tier Commission Plan

Revenue Share Plan

Under this plan, the Affiliate shall be entitled to receive, with respect to each calendar day during the Term, 30% (thirty percent) of the Net Revenues generated from the Affiliate’s Customer(s) during such month.

Second Tier Commission Plan

If explicitly approved by CryptoTheorem in writing in its sole discretion on a case by case basis, an Affiliate may also be entitled to receive an additional amount for any Second Tier Affiliate that it introduced to CryptoTheorem.

Under such Plan, the Affiliate shall be entitled to receive an amount equal to 5% of the Net Revenues generated by the Second Tier Affiliate’s Customers up-to an aggregated maximum amount of $20,000 throughout the lifetime period of the Second Tier Affiliate.

CryptoTheorem may determine, in its sole discretion, that several Second Tier` Affiliates accounts maintained under the same household/control/ownership shall be considered as a single account and shall not entitle the Affiliate to Fees payable with respect to separate accounts.

Last updated: September 4, 2018

Automated Trading Risks

What risks are unique to automated trading?

Mechanical failures. The theory behind automated trading makes it seem simple: Set up the software, program the rules and watch it trade. In reality, however, automated trading is a sophisticated method of trading, yet not infallible. What that means is that if an internet connection is lost, an order might not be sent to the market. There is also the potential for a power loss, computer crash, or some other system quirk that could stop your algorithm from running or cause an anomaly.

Monitoring. Although it would be great to turn on the computer and leave for the day / week, automated trading systems do require monitoring or an alerting system. This is due to the potential for mechanical failures, such as connectivity issues, power losses or computer crashes, and to system quirks as mentioned above. It is also possible for an automated trading system to experience anomalies that could result in errant orders, missing orders, or duplicate orders. If the system is monitored and/or has an alerting system, these events can be identified and resolved quickly.

Trading Experience. Your level of trading experience with automated trading systems is important in deciding how you should choose your overall trading strategy. Highly complex strategies with many variables make it more difficult to determine whether the trades that will execute are designed to be profitable. Starting with simple automation strategies will allow you to develop experience and learn methods of trading that work best for you.

Over-optimization. Though not specific to automated trading systems, traders who employ backtesting techniques can create systems that look great on paper and perform terribly in a live market. Over-optimization refers to excessive curve-fitting that produces a trading plan that is unreliable in live trading. It is possible, for example, to tweak a strategy to achieve exceptional results on the historical data on which it was tested. Traders sometimes incorrectly assume that a trading plan should have close to 100% profitable trades or should never experience a drawdown to be a viable plan. As such, parameters can be adjusted to create a "near perfect" plan – that completely fails as soon as it is applied to a live market.

Programming discrepancies. There could be a discrepancy between the "theoretical trades" generated by the strategy and the order entry platform component that turns them into real trades. Most traders should expect a learning curve when developing automated trading systems, and it is generally a good idea to start with small trade sizes or conduct “paper trading” while the process is being refined.

No High Frequency Trading. CryptoTHeorem’s platform is NOT a high frequency trading platform. While an automated trading strategy can sent trades to the market at a high frequency, CryptoTheorem does not support the necessary speed of either market data flow or trade execution speed necessary for a high frequency trading program to function as intended. Automated trading strategies that have an over-reliance on the speed of market data and speed of execution will not be able to compete effectively with traders who have state of the art equipment and very short high speed connections to the market, in particular when the connection you are using to the internet is via a residential internet service provider.

Reliance on Risk-Reducing Orders or Strategies. With automated trading, substituting manual market monitoring with the placing of certain orders (e.g. ‘stop-loss’ orders or ‘stop-limit’ orders) which are intended to limit losses to certain amounts may not be effective because market conditions may make it impossible to execute such orders. At times, it is also difficult or impossible to liquidate a position without incurring substantial losses and CryptoTheorem’s platform does not provide a readily available manual intervention process.

Security

Is CryptoTheorem safe to use?

Our customer's security is of paramount importance to us

We spend a lot of time on our security systems, so your account is safe with us. We do NOT have permission to withdraw your funds, so in the unlikely event of a data breach, it is still impossible for hackers to access your funds. The exchanges we work with are known to spend a lot of time and money in their safety, so your funds should be secure with them.

If you want extra security enabled on your account, we suggest you to activate two-factor authentication (2FA). This helps further hardening your account security. Our websites are protected by Web Application Firewall. Our platform is hosted on dedicated servers secured in private data rooms at multiple PCI-DSS compliant colocation providers. Any saved API keys are encrypted in our systems and are loaded to memory for the minimum time it is necessary.

In the following sections you can learn more about our security practices at CryptoTheorem that allow seamless and safe operation of worlds largest algorithmic cryptocurrency trading facility serving more than 100,000 simultaneous traders among of our 10,000,000 users including more than 100,000 hedge funds world-wide.

Security by Design

• The service has no access to user funds on the exchange.
• API user keys are stored on secure servers
• Two-factor authentication via phone
• HTTPS encryption for secure communications

About Phishing Attacks

In this section you can find out everything you need to know about phishing and the way you can protect your personal data and funds. Let's take a look at it.

Phishing is a type of social engineering attack. It is a fraudulent attempt to obtain sensitive information such as username, password, 2FA code, etc, by disguising as CryptoTheorem or exchange in an electronic communication. Users are often be deceived by trusted parties such as

• Email spoofing;
• Fake website;
• Instant message with malicious link;
• Social websites with manipulated link;
• Chat with impersonated service support;
• Fake hotline or support in search engine;
• Social media fake account;
• Malware downloaded from the Internet;
• Free Wi-Fi phishing;

Protect yourself from phishing scams

It is known that the most important and weakest aspect in a security system is people. Hence, for users, viligance is key:

A spoofed message often contains subtle mistakes such as spelling mistakes, strange syntax, unsmooth wording, misspelled domain name. For example: cyrptotheorem.com, etc.

In addition, attackers will try to push users into action by creating a sense of urgency. For example, an email could threaten account expiration and urge you to verify it within a timeline or you can see a message instructed users to move asset to a secure walled to avoid loss as soon as possible.

Phishing attack protection requires steps to be taken by users.

Upgrade Google Chrome or Mozilla Firefox to the latest version. It is known that Google Chrome or Mozilla Firefox will warn users for phishing or unsafe high risk website.

The safest way to login to CryptoTheorem is only through the website.

Enable Two-factor authentication (2FA) system to level up your security. You shall not disclose your Google 2FA 16 digits backup key to anyone or any website. If your account and password were compromised credentials, since these alone are insufficient to gain entry.

Install Chrome Netcraft Extension or Firefox Netcraft Anti-Phishing Extension.

Keep your systems and application updated to avoid security bugs, and install reputable anti-virus software and keep it updated.

Moreover, please, no not connect to an untrusted wireless network.

Report Phishing

If you see any suspicious messages from someone posing as us, please contact us as soon as possible.

Can I whitelist the IP address of CryptoTheorem?

Unfortunately whitelisting IP addresses in not yet available for CryptoTheorem. This is because our platform is built on a lot of servers with a lot of IP addresses that continuously change. Servers are being added and removed often to cope with the capacity needs at different points of presence. For making it possible to add IP whitelisting for CryptoTheorem we would need to add a NAT (Network Address Translation) gateway which would defy the scaling aspect of our platform.

My account is blocked, how can I log in?

If your account has been blocket, it can have multiple causes:

1. You haven't clicked on the address given in the activation e-mail address
2. Your account has been blocked due to too many failed authentication attempts.
3. You have been blocked by one of our administrators due to a violation of our terms of service.

I have found a security bug, how to report?

We welcome every report, even if we perform penetration tests by 3rd party professional services, and have our own security team on board, there might bugs left in the system. We have contracted with OpenBugBounty.org in order to take care of communications for us and allow you to responsibly disclose your finding in a controlled manner, without further legislative action from our side.

Still have questions??

Our security engineering team is readily available 24/7 to address your security related concerns at the matter. Please feel free to contact us with your questions or security related needs.

Copyright Dispute Policy

Effective date: April 1, 2019

In accordance with the DMCA, we've adopted the policy below toward copyright infringement. We reserve the right to block access to or remove material that we believe in good faith to be copyrighted material that has been illegally copied and distributed by any of our advertisers, affiliates, content providers, members or users and remove and discontinue service to repeat offenders.

Remember that your use of CryptoTheorem's Services is at all times subject to the Terms of Use, which incorporates this Copyright Dispute Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

Procedure for Reporting Copyright Infringements.

If you believe that material or content residing on or accessible through the Services infringes your copyright (or the copyright of someone whom you are authorized to act on behalf of), please send a notice of copyright infringement containing the following information to the Atom Designated Agent to Receive Notification of Claimed Infringement (our 'Designated Agent', whose contact details are listed below):

• A physical or electronic signature of a person authorized to act on behalf of the owner of the copyright that has been allegedly infringed;
• Identification of works or materials being infringed;
• Identification of the material that is claimed to be infringing including information regarding the location of the infringing materials that the copyright owner seeks to have removed, with sufficient detail so that Company is capable of finding and verifying its existence;
• Contact information about the notifier including address, telephone number and, if available, email address;
• A statement that the notifier has a good faith belief that the material identified is not authorized by the copyright owner, its agent, or the law;
• and A statement made under penalty of perjury that the information provided is accurate and the notifying party is authorized to make the complaint on behalf of the copyright owner.

Once Proper Bona Fide Infringement Notification is Received by the Designated Agent. Upon receipt of a proper notice of copyright infringement, we reserve the right to:

• remove or disable access to the infringing material;
• notify the content provider who is accused of infringement that we have removed or disabled access to the applicable material;
• and terminate such content provider's access to the Services if he or she is a repeat offender.

Procedure to Supply a Counter-Notice to the Designated Agent.

If the content provider believes that the material that was removed (or to which access was disabled) is not infringing, or the content provider believes that it has the right to post and use such material from the copyright owner, the copyright owner's agent, or, pursuant to the law, the content provider may send us a counter-notice containing the following information to the Designated Agent:

• A physical or electronic signature of the content provider;
• Identification of the material that has been removed or to which access has been disabled and the location at which the material appeared before it was removed or disabled;
• A statement that the content provider has a good faith belief that the material was removed or disabled as a result of mistake or misidentification of the material; and
• Content provider's name, address, telephone number, and, if available, email address, and a statement that such person or entity consents to the jurisdiction of the Federal Court for the judicial district in which the content provider's address is located, or, if the content provider's address is located outside the United States, for any judicial district in which Company is located, and that such person or entity will accept service of process from the person who provided notification of the alleged infringement.

If a counter-notice is received by the Designated Agent, Company may, in its discretion, send a copy of the counter-notice to the original complaining party informing that person that Company may replace the removed material or cease disabling it in 10 business days.

Unless the copyright owner files an action seeking a court order against the content provider accused of committing infringement, the removed material may be replaced or access to it restored in 10 to 14 business days or more after receipt of the counter-notice, at Company's discretion.

Please contact Company's Designated Agent at the following address:
support@cryptotheorem.com

CONFLICT OF INTEREST POLICY

The Conflict of Interest Policy (Policy) enables CryptoTheorem (Company) to have a set of rules to better perform its activities, from the level of the procedures to that of its internal organization, in order to avoid the occurrence of conflicts of interest- the purposes or advantages, inherent or non-proprietary, own or extraneous that a particular decision intends to pursue or achieve with a transaction, which may interfere with the fulfillment of the duties, impartiality, objectivity and compliance with the Code of Conduct for Persons Subject to the Policy are obligated in the exercise of their functions or interests of the Company.

Given the commitment to transparency taken on by the Company towards its Users, here is the present conflict policy:

1. GENERAL TERMS

1.1. This document includes the Corporate Policy for Conflicts of Interest of the Company and covers, but is not limited to, the activities practiced by it in its relations with the most diverse market agents, capable of exposing the Company to situations - actual or potential - of conflict of interests.

1.2. DEFINITIONS

1.2.1. The following are some relevant concepts, such as:

1.2.1.1 Conflicts of interest can be conceptualized as a set of conditions in which a primary interest tends to be unduly influenced by a secondary interest and may occur due to (but not limited to):

(i) influences, interests or relationships that, directly or indirectly, can be considered, regardless of their result, as being incompatible with direct and objective conduct.

(ii) circumstances in which individuals and/or entities exercise their relationships, and may cause actual or potential loss or harmto the Company or its business.

(iii) financial or commercial strategies in disrepair with good management practices, which endanger sustainable results, the continuity and good image of the Company.

(iv) use of inside information for own benefit.

(v) hiring people for management positions that are not aligned with the Company's values/purposes/strategies.

2. PURPOSE AND TARGET AUDIENCE OF THIS POLICY

2.1. The main objective of this policy is to establish guidelines and guide the conduct of Employees, service providers, holders of social capital, customers, members of administrative/supervisory bodies, suppliers/commercial partners, among others ('People Subject to Politics') - with respect to the management of Conflicts of Interest, in addition to promoting all reasonable and necessary measures capable of facilitating transparency and independence in the Company's relations, as well as effectively managing conflicts of interest that may arise.

3. PRINCIPLES

3.1. The Policy is based on the following principles:

3.1.1. Prevalence of User's interests: decisions, processes and controls, should be directed to the interests of customers;

3.1.2. Responsibility: It is the responsibility of the People Subject to the Policy to disclose potential conflicts of interest;

3.1.3. Equity: third-party resource management process should prioritize equal treatment to the Users;

3.1.4. Ethics: ethical values should guide the interests at all levels, regarding the proper identification and management, including, but not limited to, immediate/rapid resolution of conflicts as they arise;

3.1.5. Compliance: Compliance with national, international and internal standards;

3.1.6. Transparency: provision of information/ service in a clear, current, and complete manner, and without the objective of misleading customers

3.1.7. Information: eliminate or reduce to a minimum the risk of occurrence of situations which could potentially generate conflicts of interest

4. CONFLICT OF INTERESTS

4.1. RESPONSIBLE PERFORMANCE

4.1.1. Persons Subject to the Policy, when acting on behalf of the Company, must do so in a responsible, diligent and transparent manner, making decisions that do not contravene the Company's interests , and always seeking to defend its good reputation, the value of its business and of its brands, the solidity and continuity of its activities. In order to avoid conflicts, it is up to the People Subject to the Policy:

(i) to harmonize their conduct with the Code of Ethics and Conduct and with this policy;

(ii) ensure that business partners whose management is under their responsibility are aware of the values expressed in the Code of Ethics and Conduct and in this policy and conduct their activities in line with those values;

(iii) report any suspected violations through the Compliance Channels, contributing to the continuous improvement of the Company.

(iv) it is up to leaders to reinforce this policy through communication as well as to ensure that their teams comply with and participate in mandatory training so that the guidelines set forth in this policy are fulfilled;

4.1.2. The Persons Subject to the Policy, understand that conflict of interests causes damages to the organization, to those involved and to society in general, since:

(i) it jeopardizes the reputation of the Company or may cause losses of various types, including financial;

(ii) it harms people and businesses;

(iii) it compromises professional performance; and

(iv) it diminishes the credibility of those involved, giving rise to suspicions about the smoothness of conduct.

4.1.3. Anyone who may find himself in a situation of conflict or potential conflict of interest should immediately discontinue the situation in which the conflict is manifested, communicating this fact in a timely manner to his direct superior. Armed with the information, the latter shall assess whether:

(i) the participation of the conflicted person produced detrimental effects or results to the Company, communicating such situation to their Board of Executive Officers and to the Audit and Compliance Board, eliminating such effects or results, if possible; or

(ii) such situation is only a potential conflict.

In this case, it will be up to the immediate superior to consult his board of directors to decide whether or not there is a conflict of interests. In any case, the Audit and Compliance Board will be available for orientation about questions through the Company's Open Channel. The Board in turn, depending on the orientation that the case requires, may submit it to the analysis by the Company's Conduct Committee .

4.1.4. When the conflict - or potential conflict - of interests occurs in the matter submitted to the deliberation of the Company's collegiate body, the conflicted person shall inform the other members and not participate in the deliberation, leaving the meeting. If there is any doubt as to the actual existence or otherwise of the conflict of interests, the collegiate must first decide whether or not it actually happens, without the participation of the member potentially impeded.

5. CONFLICT OF INTERESTS

5.1. Conflicts of interest arise when the ability to decide impartially and act responsibly are effectively or potentially undermined, with a risk of personal favoritism to the detriment of the Company's interests. Conflicts of interest can occur in real, potential or apparent ways. These are concrete situations:

5.1.1. Transactions with Related Party - Persons Subject to the Policy may indicate the hiring of service providers or other suppliers - individuals or legal entities - who, at any time, have been Persons Subject to the Policy, provided that the process is conducted in a transparent and to avoid suspicion of personal favoritism. Such contractors must, in any event, observe market conditions, without any favor because of the bond between the parties involved in the relationship. In addition, if there is a loss of independence, real, potential or apparent, due to the ties with the counterparty, the conflicted person must move away from the transaction, communicating this fact to his immediate superior who will decide on its continuity or not, through the determination of new interlocutors.

5.1.2. Provision of nominations - Employees and service providers may indicate people in their relationship cycle, including those with whom they have kinship or affective relationship, for selection and hiring processes in the Company. However, it is up to the Persons Subject to the Policy, the duty to be clear about their relationship with the right person and must assume an exempt position in the process. In the cases where there is an affective relationship, kinship or other form of potential Conflict of Interests between the nominee and the Employee or service provider, the area conducting the process must communicate to the Compliance Team through the email: support@cryptotheorem.com for deliberation before any proposal is made to the candidate.

5.1.3. Relationships between People Subject to Policies - The relationship of Kinship and the affective relationship between Employees and service providers is allowed, provided there is no level of hierarchical subordination, influence and management among those involved.

5.1.4. Corporate Participation by Persons Subject to the Policy - Corporate participation in other companies by Persons Subject to the Policy is permitted, but they may not: a) hold any participation capable of influencing decisions of companies competing with the Company (not competition), b) perform a function equal to or similar to that performed in the Company, or c) compromise the amount of time that conflicts with their activities in the Company.

5.1.5. Consistent use of the information obtained as a result of the work carried out in the Company - it is the responsibility of the Persons Subject to the Policy to manage and make conscious use of information related to work based on the ethical principles disseminated, respecting information barriers and confidentiality duties at all times;

5.1.6. External Professional Activities - Employees and service providers may perform other professional activities, paid or unpaid, outside the Company's working hours, as long as these activities do not conflict with the business (non-competition and confidentiality) and group interests and do not harm the performance of their duties. Examples of professional outside activities is participation in class councils, trade unions and associations, academic activities, artistic and commercial activities, among others.

5.1.7. Hiring New Employees and Service Providers - The areas responsible for hiring new Employees and service providers should question candidates about potential Conflicts of Interest as part of the selection process.

5.2. SUPERVISION CARE

5.2.1. It is the responsibility of the employees who supervise the duty to:

(i) actively seek to identify, mitigate and, to the extent required by Company procedures, settle disputes of interest in their area of responsibility, including in connection with any planned activities;

(ii) evaluate any Conflicts of Interest reported to them to determine if a Conflict of Interest exists;

(iii) determine, after consulting the Compliance team and other control functions, as necessary, the best course of action to resolve, manage or avoid the Conflict of Interest, including a senior management authority, whenever necessary, or withdrawal (temporary or permanent) of their supervision of a particular subject or activity;

(iv) review annually or more regularly, if necessary, any Conflict of Interest to ensure that it is managed in accordance with any agreed resolution; and

(v) assign responsibilities to the Team that reports to them in a way that does not lead to Conflicts of Interest and avoid assigning responsibilities that jeopardize the Company's independence of control.

5.3. BOARD CARE

5.3.1. The members of the board of directors must:

(i) consider the interests of the Company as an element in their decision-making process, proactively identifying the Conflicts of Interest resulting from their position in the company member and disclose such Conflicts of Interest as required by the terms of reference and applicable rules ; and

(ii) refrain from any action / abstention that could be detrimental to the Company to which they are a member of the board. Conflicts of material interest, individually and collectively, must be adequately documented, communicated, discussed and duly managed by the Compliance Team;

(iii) a Board Member should not be involved in any type of business that is in competition.

6. MECHANISMS FOR IDENTIFYING CONFLICTS OF INTERESTS

6.1. In addition to the communication mechanism open to the Persons Subject to the Policy, the identification of possible conflicts of interest can be identified in the face of the following practices:

6.1.1. Verification of the main activities that can generate conflict of interests and constant revision to identify new situations.

6.1.2. Conducting internal monitoring.

6.1.3. Communication of the Employee to his superior about any situation that will affect his objectivity and professional independence, before carrying out activity under his responsibility

7. PROCEDURES FOR THE ELIMINATION AND MITIGATION OF CONFLICTS OF INTEREST

7.1. Conflict of interest management includes procedures/adoption of appropriate measures as described:

(i) Promotion of a culture of ethics that emphasizes that all employees must be attentive to potential or actual conflicts of interest;

(ii) Disclosure of the Code of Conduct and signing of the Term of Conduct, where employees are committed to comply with domestic and international laws and regulations;

(iii) Segregation of duties and physics in order to ensure separation between those who can make decisions and those who can influence decisions;

(iii) Logical segregation so that access to information is according to the role of each employee;

(iv) Restricted treatment of privileged and customer information;

(v) Remuneration policy that does not generate a conflict of interests;

(vi) Selection of financial intermediaries according to objective and independent criteria;

(vii) Periodic review and identification of new conflicts of interest resulting from new deals;

(viii) monitoring and control by interests when identified best interests of the client.

8. TRAINING

8.1. CONTINUOUS TRAINING AND MONITORING

8.1.1. The Company will promote continuous training aimed at disseminating the guidelines of the Code of Ethics and this Policy, as well as identifying and giving opportunities to the Persons Subject to the Policy to deal with transparency and equity in the event of any conflict of interest situations.

8.1.2. The content and periodicity of these training sessions will be scheduled and performed by the Company's Audit and Compliance Board, taking into account the particularities of each sector.

8.1.3. It will be incumbent upon the Company's Audit and Compliance Board to monitor the performance and results of the training, as well as inform the directors / supervisors / administrators / controllers about the results and possible additional training needs.

9 PURCHASE OF DIGITAL ASSETS ON THE CRYPTOTHEOREM PLATFORM

9.1. All rules, guidelines and processes involving the purchase and sale of Digital Assets pass:

(i) by the Users screen, which, in a discretionary manner, determines the values that their Digital Assets will be placed in the purchase orders;

(ii) for publication of securities equally offered to the public, without any privilege or manipulation;

10. SANCTIONS

10.1. VIOLATION OF CONFLICT OF INTEREST POLICY

10.1.1. Any breach or violation of this Company's Conflict of Interest Policy will be investigated in accordance with applicable national and international laws, the Internal Code of Ethics and the Company's interests, so that appropriate actions may be taken.

10.1.2. Failure to comply with the provisions set forth herein may subject the offender to civil, labor and administrative penalties, without prejudice to other corporate disciplinary measures.

10.1.3. The Company's Audit and Compliance Board and, as the case may be, the Conduct Committee, when analyzing the noncompliance with the terms of this Policy, will consider its materiality in the context of the Company's activities and eventual recidivism of the offender.

11. CONTRACTED THIRD PARTIES

11.1 The treatment of conflicts of interest extends to contracted third parties and must observe the following practices:

(i) Analysis of contracts signed with third parties;

(ii) Due diligence process before contracted third parties;

12. FINAL PROVISIONS

12.1 Although the purpose of this policy is to cover most situations involving the management of Conflicts of Interest, new situations may arise. In order to resolve any doubts about conduct, the Compliance Team should be consulted through Compliance Channels for situations that require additional solution or guidance in order to ensure that the values expressed herein are preserved.

12.2 This policy is linked and is an integral part of the Code of Ethics and Conduct and should be interpreted in conjunction with the other policies related to the code.

12.3 The Compliance Team is responsible for providing a solution to any conflicts between the content of this policy and other internal rules of the Company.

12.4 The Compliance Team is also responsible for reviewing and updating this policy.

13. CHANNELS FOR GUIDANCE AND DENOUNCEMENT

13.1. OPEN CHANNEL

13.1.1. Without prejudice to the foregoing, in case of doubts or denunciations related to the matters dealt with herein, as well as any other Company policies or directives , please contact us: e-mail: support@cryptotheorem.com

13.1.2. The Company undertakes to maintain confidentiality in the determination and acceptance of denunciations / anonymous statements, as well as prohibits any act of threat, intimidation or retaliation against any person who (a) denounces violations of this Policy and any other policy or legislation applicable to the Company, or (b) express their doubts, suspicions or concerns regarding this matter.

Complaints Policy

version 1.0. - May 2020

0. Company

CryptoTheorem, company registered in the Netherlands, with business address at Herengracht 420, is legal person operating under the jurisdiction of the Netherlands (hereinafter referred as 'we', 'us', 'our company', 'company').

We are governed by the provisions of the License and other applicable legal framework for entities operating in e-gaming industry.

1. Preamble

We believe our clients should be able to provide feedback (both positive and negative) about our services and the way we provide them. Complaints handling (dispute resolution) is not only a requirement by law, it is also an essential business practice. The feedback mechanism provides the business with an opportunity to learn and improve operations.

Therefore, within this policy we set the direction for client complaint management in our company and describe the mechanisms within the company in relation to complaints handling.

This Policy is based on the concepts of:

• open, honest and cooperative business relations with clients;
• the provision of a complaints handling process for all clients;
• fair dealing in the resolution of complaints or disputes.
• fostering the highest possible standard of client relations.

The company has developed internal complaints handling procedures which it believes to be compliant with the relevant dispute handling legislation within the EEA area and which also reflects good industry practice globally, including the Netherlands and is relevant for the company having regard for:

• the size and type of our business;
• the e-gaming services offered by us;
• the nature of our client base and
• the likely number and complexity of complaints.

It is relevant to the size and nature of the e-gaming services business conducted by the company and is approved by management board. The Chief Compliance Officer will oversee the implementation of the Policy. This policy will be reviewed at least annually to ensure that it continues to comply with applicable laws.

2. Definitions

Case owner means company's employee responsible for the settlement process of specific client's complaint. Case owner can be Complaints Manager or Chief Compliance Officer, depending on the level of the complaint.

Client means consumer and merchant, which is in business relationship with the company. According to this Policy client is also complainant.

Client Complaint Management System means IT supporting system (back-office) is using for complaints management.

Complaints Management Function means company's Chief Compliance Officer respectively the Data Protection Officer, including escalation and reporting obligations to the Management Board.

Complaint means an expression of dissatisfaction made to us in relation to its products and services under applicable laws and regulations (e.g. the above listed and any other laws, depending on the concrete circumstances., communicated through the official channels mentioned below.

Complaints management means complete settlement process of all complaints sent to us by clients.

3. Definitions

I. Purpose of the Policy

(1) Values: we are committed to delivering high quality services that respond to the community's needs. Company values the benefits of handling complaints in a prompt, responsive, effective, efficient, fair, transparent and consistent manner.

(2) Goals: our goal with this Policy is to cover procedures relating filling the complaint by the client, procedures relating to receipt of complaints, the opening of complaint files and the internal management of complaints (complaints management). This Policy is an important control document and covers both regulatory and business requirements.

(3) Objectives: key policy objectives are:

Client-focused service delivery. Providing the company's client with the best possible customer experience through ensuring full transparency for the clients:

• providing a standardized way of dealing with client complaints;
• having a set process in relation as to the recording and reporting of client complaints;
• having a systematic approach to reviewing client complaints as means to improving client service and satisfaction;
• Supportive and effective complaints management:
• ensuring consistency with the complaints management;
• ensuring delivery of high standards of service in relation to complaints management;
• giving guidance to the company's stuff with regards to appropriate complaints management;
• ensuring company observes all regulatory and procedural requirements in relation to information received through complaints and comments, including data protection requirements.
• Business improvement: complaints are a valuable source of feedback that help us find opportunities for staff and business improvement by using complaints data to identify areas where processes and systems can be improved.

In addition to any immediate remedial actions required in the handling of specific complaints companywill on an ongoing basis review and analyze complaints in general to identify potential hot spots and areas for improvement. We will ensure that no client will in any way be disadvantaged as a result of making a complaint. To allow us to fully and fairly investigate a complaint, we would expect the client to make us aware of the cause of the complaint as soon as possible of the issue arising.

II. Scope of the Policy/Types of the compliant handled

(1) In scope:

complaints received from clients, business partners as well as anonymous complaints and complaints from general public.

In line with the foregoing, we will investigate a Complaint, if it is submitted to us, in accordance with the Complaint Handling Policy set forth herein.

(2) Beyond scope:

• decisions involving the interpretation of the relevant laws, courts decisions or tribunals;
• complaints that do not meet requirements set forth in this Policy e.g. complaints that are incomplete or not sufficiently specific or different kinds of vague allegations without supporting documents;
• complaints (in any kind of form) submitted by public authorities;
• complaints submitted by company's employees (employment relationship related matters).

If the Complaint or dispute cannot be resolved internally by us in accordance with our Policy set out herein, we may refer the matter to the Group Ombudsman, as stipulated in section 8 of this Policy, or the competent external authorities / courts.

III. Complaints management principles

Management principles for each complaint settlement process are:

• Open, honest and cooperative business relations with clients;
• processing of data and handling of complaints in accordance with the applicable data protection provisions and any other applicable specific legislation fostering the highest possible standards of client relations;
• response to complaints shall be at no cost to the client (complainant);
• maintaining transparent approach to complaints management by publishing the complaints-handling process on a publicly available section on company's website;
• ensuring fair, prompt and efficient response to complaints
• addressing and responding to all questions of the complaint
• identifying and mitigating possible conflicts;
• ensuring procedural fairness, consistency and effectives in complaints management as well as the disputes resolution;
• ensuring appropriate level of confidentiality is maintained;
• having a systematic approach to reviewing complaints in order to improve the overall business process and identify and address issues before they become systemic and potentially reportable, and potential legal and operational risks, eg by: analyzing the causes of individual complaints so as to identify root causes common to types of complaint;
• considering whether such root causes may also affect other processes or products, including those not directly complained of;
• correcting, where reasonable to do so, such root causes;
• properly documenting ECR's actions in addressing and resolving the complaints.

IV. Complaints management framework

Our client complaint management system is part of a broader system for managing various types of complaints;

Complaints are managed depending on the type of issue reported;

This policy does not replace or override policies and procedures regarding staff performance matters, corruption, disciplinary and grievance processes, or complaints dealt with under specific legislation;

The diagram below shows the different processes for managing complaints in the company:

4. Responsibilities

V. Levels of complaints management

(1) From the functional perspective, company's complaints management system consists of 5 steps: internal compliance handling, assessment and resolution, internal review, external review and post-analysis. From the organizational perspective, there exist 3 levels of management, whereas two levels are internal, third level is external:

INTERNAL COMPLIANCE HANDLING AND RESOLUTION

Steps 1, 2 and 5 are the steps that are usually followed when dealing with complaints covered by this Policy.

Steps are followed as required or when requested.

Once a complaint is resolved, the additional step of 'monitor, review and report' is essential for business improvement and informed decision making.

(2) Compliance Officer is responsible for level 1 complaints.

(3) In exceptional cases, level 1 complaints shall escalate directly to level 2 complaints:

complex complaints, according to paragraph three of article 5 of this Policy, including complaints with potentially reportable, and potential legal , operational and security risks, affecting several clients, products or services

Complaints Officer misses the deadline for solving the complaint, according to first paragraph of article 12 of this Policy.

(4) Complaints not solved by Complaints Officer to the client's satisfaction, shall be referred to Chief Compliance Officer for level 2 complaint settlement process.

(5) Complaints not solved by Chief Compliance Officer to the client's satisfaction, shall be referred to Group Ombudsman for level 3 complaint settlement process.

(6) Client cannot submit directly level 2 or level 3 complaint.

VI. Complaints Officer

(1) Complaints Officer acts as a case owner for level 1 complaints, which means he is responsible to internally or externally coordinate each complaint settlement process. (2) Complaints Officer liabilities related to level 1 complaints are:

determination whether complaint falls within the scope of this Policy;

prompt an appropriate resolution of client's complaints;

ensuring that all complaints are appropriately logged and regularly monitored for timely response and remedial action into Client Complaint Management System;

provision of resolution status to the client and

communication of the resolution outcome on all complaints.

(3) In case there are several Complaints officers:

Chief Compliance Officer assigns specific complaint to case owner (Complaint Officer) within the Client Complaint Management System;

within Client Complaint Management System case owners has only access to their case records.

(4) Complaints officer may propose to Chief Compliance Officer to escalate level 1 complaint to level 2 complaint.

VII. Chief Compliance Officer

(1) Chief Compliance officer is ultimately responsible for each complaint settlement process and for complaints management in general.

(2) Chief Compliance Officer is responsible (case owner) for level 2 complaints, which means he is responsible to internally or externally coordinate each complaint settlement process.

(3) Chief Compliance Officer becomes case owner in the event of escalation of level 1 complaint, according to third paragraph of article 3 of this Policy.

(4) Chief Compliance Officer liabilities related to level 2 complaints are all responsibilities stipulated in third paragraph of article 5 of this Policy. Chief Compliance Officer is responsible for:

ensuring the proper escalation of clients complaints;

provision of reports for management, if so requested and regularly, at least annually

creating case owners in the Client Complaint Management System;

assessing appropriateness and effectiveness of implemented processes, measures and risk of complaint handling violations and, where required, necessary remedial actions,

preparing root cause analysis and initiation of service improvement actions as applicable.

(5) Chief Compliance Officer shall regularly monitor the complaint resolution process (at least weekly) for effective and timely handling via the Client Complaint Management System. All complaints shall be reviewed by Chief Compliance Officer upon successful resolution of the complaints by the Complaints Officer.

(6) Chief Compliance Officer may consider need to escalate specific level 1 or level 2 complaint to the management board or directly to competent authorities.

VIII. Ombudsman

(1) All level 2 complaints which have not been resolved to the satisfaction of the client escalate to level 3 complaints.

(2) External Ombudsman is responsible for complaint settlement process for all level 3 complaints.

(3) External Ombudsman is independent specialist for complaints management.

(4) Clients submits level 3 complaint directly to the External Ombudsman.

(5) On written request by the External Ombudsman, company forwards Complaint file for level 3 complaint not later than 2 (two) business days after receipt of such request.

5. Complaint making process

IX. Submitting complaint

(1) Clients wishing to file a complaint must do so in writing by letter or preferably by e-mail. Clients who wish to file a Formal Complaint with the Company's Compliance Officer can do so, at any time, in writing by completing and sending the relevant document named Complaints Form, which is available to download from the company´s website. Complaints can be received through any of the following means:

e-mail support@cryptotheorem.com;

(2) If the client's account of the situation is incomplete, company has right to contact the client to obtain further written information.

X. Content of the complaint

(1) Complaint should include minimum the following information:

• client's name and contact details (e-mail, phone number);
• client's relationship with the company;
• client's contact person within the company (if applicable);
• the nature of the complaint;
• the signature of the complaint (if applicable).

(2) In case complaint does not include all information stipulated in the previous paragraph, case owner has right to request in writing from the client to provide missing information and documentation.

(3) Client is required to provide requested info not later than 5 (five) business days after receiving request from case owner.

(4) If client doesn't provide requested info within the deadline stipulated in the previous paragraph and if there is not enough information to continue with the complaint settlement process or in case of any other event as stipulated in the second paragraph of article 2, Chief Compliance Officer has right to dismiss the complaint.

6. Complaint's management

XI. Receiving complaint

(1) All complaints, typically received by the channels mentioned in art. 9 above are immediately entered in a record kept in Client Complaint Management System by Complaint Officer. Complaint Officer must also ensure that the contact details of the client are included to enable direct communication with the client upon resolution of the complaint by the company. Additionally, Complaint Officer should ensure to enter all complaint related material information and process steps in the system, namely the following information:

• details of the identity of the customer who filed the complaint, allocated Reference number;
• details of the complaint owner that undertook to provide the service to the customer;
• date of receipt of the complaint;
• date of complaint acknowledgment issued;
• details of the complaint - full description, including dates, figures, amounts, list of supporting documentation etc.; in case of databreach, extent of data brach, type and volume of personal data involved,
• extent in e-gaming terms of the potential loss that the customer claims he/she has suffered or as it is derived from the content of the complaint;
• investigations, risk assessment and resulting outcome (customer type; suspected root cause; outcome; remedial action taken)
• date and in summary, the content of the reply/ies of the company (including list of supporting documentation) to the said complaint;
• Notifications/reportings.
• Claim reference (if applicable);.
• Date resolved/closed.

(2) All complaints received via website shall be automatically integrated into Client Complaint Management System..

(3) Client Complaint Management System shall automatically forward a notification to the client acknowledging receipt of the complaint along with the Reference Number. Company should communicate in a plain language which is clearly understood. This notification will confirm that company is taking the necessary action needed to resolve the complaint and will get back to the Client in writing about the findings of our investigations once the cause of the complaint has been reviewed and will also provide an approximate timescale up to 7 days in order to do.

(4) For easy reference and retrieval, Complaint Officer apply the following procedure:.

upon receiving the complaint, company must register the complaint directly to an internal register, giving it a unique reference number;.

the unique reference number is communicated to the complainant;.

company informs the complainant that he should use the said reference number in all future contact with the company, the E-gaming Ombudsman regarding the specific complaint.

XII. Solving complaint

(1) Complaint settlement process is concluded with issued final decision (article 13) or with the dismissal of the compliant by the Chief Compliance Officer (fourth paragraph of article 10).

(2) All level 1 complaints shall be resolved not later than 10 (ten) business days after the receipt of the compliant from the client.

(3) Complaints not solved within the deadline from the previous paragraph, are directly escalated to level 2 complaint, according to article 3 of this Policy.

(4) All level 2 complaints shall be resolved not later than 15 (fifteen) business days after the receipt of the compliant from the client.

(5) Complaints with immediate resolution shall be communicated to the client same day of receipt.

(6) All resolved complaints shall be logged as such in Client Complaint Management System.

XIII. Final decision

(1) Once the issue has been resolved, responsible case owner prepares final decision in writing, inputs in to the system/register a closed status for the complaint indicating description of taken actions.

(2) Final decision includes:

description of the final decision (clearly marked as final decision);

indication of all the facts that served as a basis for the final decision;

copies of all the relevant documentation;

instructions how to proceed in case final decision is not solved in client's satisfaction (escalation of the complaint), with contact details of the Compliance Officer.

(3) Final decision is forwarded to client using the same communication channel that client used when submitting the compliant.

(4) The Compliance Officer shall on an on-going basis analyze complaints-handling data, to ensure that company employees identify and address any recurring or systemic problems, and potential legal and operational risks.

XIV. Unresolved Disputes and External Dispute Handling

(1) Every complaint needs to be answered within 15 working days of the complaint first received, at the latest. If exceptionally, the complaint cannot be processed within this time period company will inform the client in writing that the investigation is continuing, the reasons for the delay and when company expects to address and respond to the complaint at the latest, observing the maximum time period of 35 working days of the complaint first received.

(2) When a final decision does not fully satisfy the complainant's demands, the company should notify in writing the complainant using a thorough explanation of its position on the complaint and set out the complainant�s option to maintain the complaint e.g. through the External Ombudsman, or the relevant Courts. Based on client's written request, the complaint file will then be transferred to the External Conciliation Board / Data protection Office of or the relevant Courts. The client has also the right to contact these authorities at any time on his own initiative.

VII. Record keeping

XV. Complaint file

Each complaint file includes information listed in 11(1) article. In addition, complaint file shall include the following information:

• a unique reference number
• a copy of a client's complaint;
• a copy of the acknowledgement of receipt sent to the client (complainant);
• results of the complaint handling process, including supporting documents;
• a copy of the final decision.

XVI. Internal register

(1) Company will keep a record of all complaints files in a complaints register to be managed by Chief Compliance Officer.

(2) Each complaint file is transferred to complaints register once specific complaint settlement process is concluded.

(3) Records of complaints will be retained for a period of 10 (ten) years, unless specific legislation requires a longer retention period.