Policies

1. Introduction

1.1 This document, known as the Standard Business Terms (hereinafter referred to as "the Terms"), is part of the agreement between the Client (hereinafter referred to as "the Client") and Zenora Capital (hereinafter referred to as "Zenora" or "the Company") regarding the Client's account opening, trading activities, and related services with the Company. 1.2 The complete agreement between the Company and the Client consists of the following documents:

• Standard Business Term
• Financial Terms (Fees & Charges)
• Customer Account Opening Application and Account Information
• Risk Disclosure Documents
• Privacy Policy
• Conflict of Interest Policy
• Order Fulfillment Policy
• Complaint Handling Procedure

The aforementioned documents are collectively referred to as “this agreement”.

1.3 Before opening an account or conducting any transaction, the client should fully read and understand all the contents of this Agreement. Once the client registers an account, logs into the platform, or conducts a transaction, it is deemed that the client has accepted and agreed to all the terms of this Agreement.

2. Definitions

Unless the context otherwise requires, the following terms have the following meanings:
Access Code: Refers to the username, password, or other security verification information provided by the Company to clients for accessing the trading platform.

Account Statement: Refers to a record of transactions, fees, and fund changes in a client's account. Applicable Laws and Regulations: Refers to any laws, regulatory rules, or market regulations applicable to the Company or its clients.

Contract for Difference (CFD): Refers to a financial derivative instrument based on changes in the price of an underlying asset.

Client Funds: Refers to funds held or managed by the Company on behalf of clients.

Margin: Refers to funds that clients need to deposit to maintain open positions.

Open Positions: Refers to trades that have not yet been settled or closed.

Order: Refers to a buy or sell instruction submitted by a client through the trading platform.

Transaction: Refers to any buying or selling transaction between a client and the Company regarding financial instruments.

3. Regulatory Disclosure

3.1 Zenora Capital is a financial services brand that is legally incorporated and operates in accordance with applicable laws and regulatory requirements.

3.2 The Company conducts its business in accordance with applicable laws, regulatory rules, and internal control systems, and has established corresponding complaint handling procedures.

3.3 Customers who wish to file a complaint should contact the Company through its designated customer service channels or via email.

4. Risk Confirmation

4.1 The client acknowledges and understands that trading in financial derivatives carries a high level of risk and may result in the loss of all invested capital.

4.2 Leveraged trading may amplify both gains and losses.

4.3 Clients should fully assess their own financial situation, investment experience, and risk tolerance before engaging in any transaction.

4.4 This company makes no guarantees regarding any investment returns or trading results.

5. Client Classification

5.1 In accordance with regulatory requirements, our company classifies customers into the following categories:

• Retail Customers
• Professional Customers
• Qualified Counterparties

5.2 Different customer categories are subject to different levels of regulatory protection.

5.3 Customers may apply to our company for reclassification, but must meet relevant conditions and applicable regulatory requirements.

6. Identity

6.1 Unless otherwise agreed in writing, this company will act as the counterparty in transactions with clients.

6.2 Clients conduct transactions in their own name and assume corresponding transaction responsibilities.

7. Products and Services

7.1 Our company provides clients with trading services for the following financial products:

• Forex
• Precious Metals
• Indices
• Commodities
• Contracts for Difference（CFD）

7.2 The trading services provided by our company are handled as Execution Only.

7.3 Our company does not provide investment advice to clients.

8. Trading Platform

8.1 Clients access their accounts and conduct transactions through the trading platform.

8.2 Clients should safeguard their account passwords and access codes.

8.3 If unauthorized use of the account is discovered, the client should immediately notify the company.

9. Trade Execution

9.1 The client submits an order through the trading platform.

9.2 The transaction becomes effective only after the company confirms its execution.

9.3 The company reserves the right to refuse to execute any order.

10. Transaction Confirmation and Account Records

10.1 Our company provides transaction confirmations and account statements to clients through the trading platform.

10.2 Clients should check their account records regularly.

10.3 If a client discovers any errors, they should notify our company within 2 business days.

11. Joint Accounts

11.1 Joint account holders bear joint and several liability for the account's obligations.

11.2 Any account holder may operate the account.

12. Fees and Commissions

12.1 Clients are required to pay the following fees:

• Trading Commissions
• Spread
• Overnight Interests
• Platform Fees

12.2 The company may adjust the fee structure at any time based on business, market, or regulatory needs.

12.3 If a client's account remains inactive for an extended period, the company may charge a management fee.

13. Deposits and Withdrawals

13.1 Customers may deposit funds via bank transfer or other supported methods.

13.2 The withdrawal account must match the customer's identity.

13.3 The company reserves the right to conduct fund verification when necessary.

14. Client Funds

14.1 Customer funds will be managed in accordance with applicable laws and regulations.

14.2 Customer funds may be held in banks or financial institutions.

14.3 To the extent permitted by law, the Company shall not be liable for the bankruptcy of banks or third-party institutions.

15. Conflict of Interests

15.1 There may be potential conflicts of interest in the Company's transactions.

15.2 The Company will manage such conflicts through internal policies.

16. Leverage and Margin

16.1 Clients must maintain sufficient margin.

16.2 If the account margin is insufficient, the company may forcibly liquidate the positions.

16.3 The company is not obligated to provide advance notice of margin calls.

17. Default

The following constitute a default:

• Failure to fulfill payment obligations
• Providing false information
• Violation of laws and regulations
• Abnormal account transactions

In the event of a default, the Company may take the following measures:

• Close out positions
• Freeze account
• Terminate service

18. Force Majeure

The Company shall not be liable for losses caused by the following events:

• War
• Natural disasters
• Network or system failures
• Government regulatory measures

19. Limitation of Liability

Except as required by law, the Company shall not be liable for the following losses:

• Market volatility losses
• Communication failures
• Third-party service issues

20. Termination

20.1 Customers may close their accounts at any time.

20.2 The Company may terminate customer accounts under reasonable circumstances.

21. Notifications

21.1 The Company may notify customers through the following methods:

• Email
• Platform messages
• Website announcements

22. Intellectual Property

22.1 The trading platform, software, and all technologies are the property of this company or its partners.

22.2 Clients may not copy or distribute the related content.

23. Data Protection

Our company will process customer personal data in accordance with our privacy policy.

24. Governing Law

This Agreement shall be governed by the laws of the applicable jurisdiction.

All disputes shall be settled in the courts of the relevant jurisdiction.

25. Risk Disclosure

The client acknowledges that trading in financial derivatives carries a high degree of risk and may result in the loss of all funds.

The client should only use funds they can afford to lose for trading.

Zenora Capital (hereinafter referred to as "Zenora" or "the Company") is committed to protecting the personal information security of its customers and visitors. This Privacy Policy explains how we collect, use, store, and protect your personal data when you visit our website, use our services, or interact with us in business.

We will make reasonable efforts to ensure that your personal information processing complies with applicable data protection laws and relevant regulatory requirements. This website is not intended for individuals under the age of 18, and we do not proactively collect information from minors.

Please carefully read this Privacy Policy and other privacy statements that we may provide in specific scenarios to fully understand how we collect and use data. This policy is intended to supplement other relevant explanations, not replace them.

1. What Data Do We Collect?

To provide you with services, we may collect certain personal information when you visit our website or interact with us. "Personal information" refers to any information that can identify an individual, such as name, email address, phone number, or other contact information.

We may collect and process the following categories of data:

• Identification information: such as name, email address, phone number, etc.
• Technical information: such as IP address, browser type, device information, operating system, and access time.
• Usage information: such as pages visited, time spent on the site, click behavior, and website navigation paths.
• Contact information: such as information submitted through website forms or email.

We do not proactively collect sensitive categories of personal data, such as race, religious beliefs, political opinions, health information, or biometric data.

2. How We Collect Your Data?

We may collect your personal information through the following methods:

Direct Interaction: You may provide us with personal information when you fill out forms, contact us, subscribe to services, apply for products, or participate in activities.

Automated Technology: When you visit our website, we may automatically collect technical and usage information through cookies, server logs, or similar technologies.

Third-Party Sources: In some cases, we may obtain data about website access behavior from third-party analytics service providers (such as Google Analytics).

3. How We Use Your Data?

We may use your personal data for the following purposes:

• To provide, manage, and improve our products and services
• To process customer inquiries and support requests
• To analyze website usage to optimize user experience
• To send you relevant product or service information with your consent
• To prevent fraud and maintain platform security

4. How We Store Your Data?

We have implemented reasonable technical and organizational security measures to prevent your personal data from being accessed, lost, misused, or disclosed without authorization.

Our employees, agents, or authorized partners will only access your personal data when necessary for business purposes, and will be subject to strict confidentiality obligations.

5. Your Data Protection Rights

To the extent permitted by applicable law, you may have the following rights:

Right of Access: You have the right to request access to a copy of your personal data held by us.

Right of Correction: You have the right to request that we correct inaccurate or incomplete personal data.

Right of Erasure: In certain circumstances, you have the right to request the erasure of your personal data.

Right of Restriction of Processing: You have the right to request that we restrict the processing of your personal data.

Right of Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format.

Right to Withdraw Consent: You may withdraw your consent at any time if we process data based on your consent.

Before using the financial trading services offered by Zenora Capital, you should fully understand the nature of the relevant financial products and the risks they may involve. Trading in forex, contracts for difference (CFDs), precious metals, indices, and other leveraged products carries a high degree of risk and is not suitable for all investors. Before engaging in any trading, you should carefully assess whether such trading is suitable for you based on your investment objectives, financial situation, investment experience, and risk tolerance.

This Risk Disclosure Statement aims to help clients understand the main risks that may be involved in financial trading, but it does not cover all potential risks. Clients should ensure that they fully understand the relevant risks before trading and seek independent professional advice if necessary.

1. Leveraged Trading Risk

Trading on margin means you only need to invest a portion of the total value of your trade to establish a position. While leverage can amplify potential gains, it also amplifies potential losses. Even small market price fluctuations can have a significant impact on your account and could result in the loss of your entire invested capital.

2. Market Volatility Risk

Financial market prices can be affected by a variety of factors, including but not limited to macroeconomic data, interest rate changes, political events, geopolitical conflicts, policy adjustments, and changes in market sentiment. These factors can cause significant market price volatility, resulting in rapid and unpredictable changes in profits and losses for clients' trading positions.

3. Liquidity Risk

Market liquidity may decrease during periods of high market volatility, insufficient trading volume, the release of major economic events, or market opening. In such cases, client orders may not be executed at the expected price, or slippage, delayed execution, or even failure to execute may occur.

4. Price Gap Risks

After weekends, holidays, or major market events, market prices may jump directly to new levels instead of gradually filling in gaps at intermediate prices. In such cases, stop-loss or limit orders may not be executed at the set price, and the actual execution price may deviate significantly from expectations.

5. Margin and Forced Liquidation Risks

Clients are responsible for maintaining sufficient margin levels to support their open positions. If account equity falls below the required margin level and the client fails to replenish funds in a timely manner, Zenora Capital reserves the right to force liquidation of some or all of the client's positions without prior notice.

6. Technology and System Risks

Online trading relies on internet connectivity, electronic devices, software systems, and third-party network services. Due to system failures, network latency, telecommunications problems, or other technical reasons, clients may be unable to access the trading platform, place orders, or manage their accounts in a timely manner.

7. Third Party Risks

In the process of trade execution, fund processing, and technical support, the company may use third-party services such as banks, payment institutions, liquidity providers, or technology providers. Although the company carefully selects its partners, it cannot completely eliminate the risk of operational problems or service interruptions by third-party institutions.

8. Regulatory and Legal Risks

Laws and regulations in different jurisdictions may change, and these changes may affect financial markets, trading conditions, or clients' trading activities. Clients should familiarize themselves with the applicable laws and regulations in their jurisdiction and ensure that their trading activities comply with local legal requirements.

9. Non-Investment Advice Disclaimer

The services provided by Zenora Capital are typically execution services. Market information, technical analysis, or research materials provided by the company are for informational purposes only and do not constitute investment advice, investment recommendations, or a guarantee of returns. Clients should make their own independent trading decisions based on their own judgment.

Zenora Capital is committed to establishing and continuously improving its anti-money laundering, counter-terrorist financing, and related compliance control mechanisms to prevent its products, services, accounts, and trading channels from being used for any illicit financial activities, terrorist financing, fraud, sanctions evasion, or other illegal activities.

This policy applies to all clients, potential clients, authorized representatives, beneficial owners, and related parties with whom the company has a business relationship.

Clients should fully read and understand this policy before applying for an account, submitting identity information, depositing or withdrawing funds, initiating transactions, or continuing to use the company's services.

1. Policy Objectives

This policy aims to ensure that Zenora Capital, in accordance with applicable laws and regulations, regulatory requirements, and internal control standards, reasonably identifies, reviews, monitors, and manages client identities, sources of funds, account activities, transaction behavior, and high-risk situations, and takes measures such as restriction, denial, freezing, termination, or reporting as necessary.

2. Client Due Diligence

Before establishing a business relationship, our company has the right to require customers to complete a due diligence process and submit information that our company deems reasonable and necessary, including but not limited to:

• Valid identity documents
• Proof of address
• Contact information and occupation
• Explanation of source of funds and wealth
• Company registration documents, equity structure, and information on the ultimate beneficial owners
• Other supplementary documents or explanations required by our company based on risk control requirements

If a customer fails to complete the identity verification as required, or if the information submitted is false, incomplete, outdated, or unverifiable, our company has the right to refuse account opening, delay review, restrict account functions, or terminate the business relationship.

3. Ongoing Due Diligence

Client due diligence is not a one-time procedure. Our company may conduct ongoing due diligence on clients throughout the business relationship, based on their risk level, account activity, transaction behavior, changes in information, regulatory requirements, or internal risk control needs.

Our company has the right to request clients to update their identity information, resubmit supporting documents, provide supplementary explanations of funds, or undergo further verification.

If a client fails to cooperate, our company has the right to take measures such as restricting trading, restricting withdrawals, suspending services, or terminating the relationship.

4. Fund Source Verification

Clients should ensure that the funds they deposit with our company are legal, genuine, clear, and reasonably explainable.

Our company may, based on the client's risk level, deposit size, transaction behavior, or unusual signals, request clients to submit bank statements, income statements, tax documents, business contracts, asset certificates, or other supporting materials to verify the source of funds and wealth.

If a customer cannot reasonably prove the source of funds, or if the company believes that the funds are abnormal, complex, concealed, have no obvious economic purpose, or cannot be verified, the company has the right to refuse to accept the funds, restrict the account, suspend withdrawals, or terminate the business relationship.

5. Account and Transaction Monitoring

Our company has the right to continuously monitor client accounts and transaction activities to identify abnormal patterns, suspicious transactions, or potential risk events,

including but not limited to:

• Fund flows that are clearly inconsistent with the client's identity, occupation, income, or historical behavior
• Frequent, large, fragmented, or economically unreasonable deposits and withdrawals
• Abnormally short-term transactions or account operations without substantial trading purpose
• Suspected third-party payment or collection activities or fund transactions that do not match the client's real-name information
• Activities that may involve money laundering, terrorist financing, fraud, sanctions evasion, or other illegal activities.

6. Third Party Payment Restrictions

Unless expressly agreed in writing by the Company or otherwise stipulated by laws and regulations, Zenora Capital in principle, does not accept payments from third parties of unknown origin, and does not allow clients to withdraw funds to third-party accounts whose registered names do not match the account information.

If a client uses a third-party account for payment, or requests funds to be transferred to a third-party account, the Company reserves the right to refuse the transaction and request further supporting documentation from the client.

7. High-Risk Clients and Sanctions

For clients from high-risk regions, involved in high-risk industries, with complex equity structures, opaque beneficial owners, politically public figures (PEPs), or those deemed by the company to pose a high compliance risk, the company may apply stricter due diligence standards.

The company reserves the right to conduct sanctions screening on clients, counterparties, and funding channels in accordance with applicable laws, international sanctions lists, regulatory requirements, and internal policies.

If a client is found to pose a sanctions risk, the company has the right to refuse account opening, restrict services, freeze accounts, or terminate business relationships.

8. Suspicious Activities

If our company reasonably suspects that a client's account, funds, transactions, or related activities involve money laundering, terrorist financing, fraud, identity theft, sanctions evasion, or other illegal or irregular risks, our company has the right to take one or more of the following measures without prior notice to the client:

• Requesting the client to provide supplementary information, transaction background, or an explanation of the purpose of funds
• Delaying, refusing, or returning deposits
• Restricting, delaying, or refusing withdrawal requests
• Restricting account login, transactions, transfers, or other functions
• Freezing the account or terminating the business relationship
• Reporting to regulatory agencies, law enforcement agencies, judicial authorities, or other legally authorized bodies

9. Record Keeping and Information Disclosure

The Company has the right to retain customer identity information, account information, transaction records, communication records, and other materials related to anti-money laundering reviews, in accordance with applicable laws, regulatory requirements, and internal compliance systems.

To the extent permitted or required by law, the Company may disclose relevant information to regulatory agencies, law enforcement agencies, judicial authorities, auditing firms, or other legally authorized agencies, and the customer understands and agrees to this.

10. Client Obligations

The client promises to:

• Provide true, accurate, complete, and up-to-date identity, account, and contact information
• Ensure the legality and reasonable explanation of the source of funds
• Not use the Company's accounts, services, or platform to engage in any illegal activities
• Cooperate promptly with the Company's identity verification, due diligence, and supplementary information when requested by the Company
• Notify the Company promptly of any significant changes to information, identity, or source of funds.

11. Policy Updates

The Company may revise this Anti-Money Laundering Policy from time to time based on changes in laws and regulations, regulatory requirements, business development, and internal control needs. The latest version will be published through the Company's website, platform announcements, or other reasonable means.