Termes & Conditions

1 – BEST INTEREST AND ORDER EXECUTION POLICY

Legal framework: The Chartoption Company (Hereinafter, “the Company” or “Chartoption”) is a company engaged to act towards its client or prospective client (Hereinafter, “the Client”), in accordance with this “Best Interest and Order Execution” policy (“the Policy”).

This Policy aims to ensure compliance with the following legislative requirements: Provision of Investment Services, the Exercise of Investment Activities, the Operation of Regulated Markets and Other Related Matters Law 144(I)/2007, as periodically amended (Hereinafter, “the Law”).

In accordance with the Law, the Company will proceed to the establishment and maintenance of an Order Execution Policy, in order to ensure compliance with the obligation to execute orders on terms most favorable to the clients and to achieve the best possible results for its clients, taking into consideration its clients’ ability, needs and trading policies, when applicable and possible.

Scope : This Policy is applicable for both Retail and Professional Clients (as defined in the Company’s Client Classification Policy). If the Company classifies a Client as an Eligible Counterparty, this Policy shall not apply to such an Eligible Counterparty.

This Policy applies when receiving and transmitting Client Orders or executing Client Orders for the Client for all the types of Binary Options offered by the Company.

We will be executing orders “on your behalf” where you legitimately rely on us to protect your interests in relation to the pricing or other aspects of the transaction that may be affected by how we execute the Order..

Factors :  The Company shall take all reasonable steps to provide the best possible results for its Clients taking into account the following factors when executing Clients’ Orders against the Company’s quoted prices:

Price: The price for a given type of Binary Option is calculated by reference to the price of the relevant underlying asset, which the Company obtains from third party external reference sources.

Prices are fixed on the Company’s online trading Platform. The Company shall update the prices as frequently as the limitations of technology and communications links allow. The Company reviews its third party external reference sources periodically, to ensure that the data remains competitive. The Company will not quote any price outside the Company’s operations time, therefore no Orders can be placed by the Client during that time.

Costs.

Rapidity of Execution: The Company does not execute the Client Order in Binary Options as a principal to principal against the Client, i.e. the Company is not the Execution Venue (as defined in Commission Directive 2006/73/EC implementing MiFID) for the execution of the Client’s Order. The Company transmits Client Orders or arranges for their execution with third party (ies). However, the Company will make its best efforts to execute Client’s Orders with celerity, taking into account technology and communications links limitations.

Probability of Execution: When the Company transmits Orders for Execution or executes them with another party, execution may sometimes be delicate. The probability of execution depends on the availability of prices of other markets, makers/financial institutions.

It may not be possible to arrange an Order for execution in some cases. In the event that the Company is unable to proceed with an Order with regard to price or size or other reason, the Order will not be executed.

The Company is entitled, in accordance with the Client’s Agreement/General Terms and Conditions, at any time and at its discretion, without any notice, to decline, refuse to transmit any Order or to arrange for the execution of any Order, Request or Client’s Instruction.
Size of Order.
Probability of settlement.

Market Impact: Some factors may rapidly affect the price of the underlying assets from which the Company’s quoted price is derived and may also affect other factors listed herein. The Company will take all reasonable steps to provide the best possible result for its Clients.

The above factors list is not exhaustive. When there is a specific instruction from the Client, the Company shall make sure that the Client’s Order shall be executed according to this specific instruction.

Professional criteria : The Company is engaged to act in accordance with the above factors and engagements in order to provide the Best Execution, by using its professional experience in the light of the available market information, and taking into account the following criteria:

The characteristics of the Client Order.
The characteristics of the Binary Options that are the subject of that Order.
The characteristics of the execution venue to which that Order is directed. For Retail Clients, the best possible result shall be determined considering globally: the price of the Binary Options, the costs related to execution, (including all expenses incurred by the Client directly related to the execution of such Order), execution venue fees, clearing and settlement fees and any other fees paid to third parties involved in the execution of the Order.

Tailor made binary options: For a specific instruction from or on behalf of a Client (e.g. fills in the required parts on the Company’s trading platform when placing an Order), the Company shall endeavour to execute the Client Order strictly in accordance with the specific instruction.

Such specific instruction can impact the Best Interest policy and therefore, not lead to the “best possible result” for the Client. Trading regulations for specific markets or/and market conditions may prevent the Company from following certain of the Client’s instructions.

Client’s engagement: The Client acknowledges and accepts that the transactions in Binary Options with the Company are not undertaken on a recognized exchange market, but are undertaken over the counter (OTC) and as such, the Client understand that such transactions are riskier than transactions made on regulated exchange markets

Professional Execution of Orders : The Company shall have the following business conduct when carrying out Client Orders:

Ensures that Orders executed on behalf of Clients are promptly and accurately recorded and allocated; Carries out otherwise comparable Client Orders sequentially and promptly unless the characteristics of the Order or prevailing market conditions make such execution impracticable; Informs a retail Client of any material difficulty immediately after becoming aware of such difficulty.

Execution Venues:  Execution Venues are the entities with which the Orders are placed. For the purposes of Orders for the Binary Options, some third Financial Institution(s) will be the Execution Venue and not the Company. Clients shall be informed of such financial institution(s) or, the main website of the Company shall name them. The list can change at the Company’s discretion by giving at least one working day prior notice to the Client.

By entering into an Agreement/accepting the Terms and Conditions (with/of) the Company for the provision of Investment Services, the Client is bounded by the Policy terms.

Miscellaneous: The Company reserves the right to review and/or amend its Policy and arrangements at its entire discretion, without any prior notice.

For further information and/or questions, please send your request and/or questions to the following e-address: info@Chartoption.com .

2 – BONUS : TERMS and CONDITIONS

a- Any bonus or benefits that are provided by ChartOption to the Client will be in accordance with the Terms and Policy of the Company. ChartOption may cancel the bonus or any benefits that have been offered in case of trade transaction abuse/misuse.

b- ChartOption reserves the right to cancel the bonus or any benefits that have been offered in case of breach of any of the terms of use, this, without any prior notification.

c- Bonus and benefit promotions may be changed or cancelled without any prior notice. Bonus and benefit promotions are for a limited in time of 6 month at the latest and per registered client at the company’s sole discretion. 

Before understanding each bonus type, it is important to understand the following:

User’s Balance

The user’s balance is an aggregation of:

  • Available cash (AC)
  • Available bonus (AB)
  • Pending bonus
  • Invested

Wallet management

Any loss in the user’s account will first be taken from the Available Cash. Once the available cash is empty, losses will be deducted from the Available Bonus (Active first). Any profit in the account will first be added to the available balance, up to its cap. Once all bonuses are full, any profit will be added to available cash.

Related deposit amount

Bonuses are given on related deposit amount. The client’s deposit can be split into related deposit amounts to give one or more bonuses on. Once the related deposit amount has been used, the bonus feature will not be available until the client makes a new deposit.

You will easily be able to determine the remaining / free related deposit amount by checking this field in the banking tab:

Bonus Cap

The bonus cap is the bonus amount originally given. This may be reduced in case of deposit. In order to prevent the user’s deposit from going to the available balance, in the case it has not reached its cap, the cap will be reduced to the current available balance (per bonus). Any bonus capped at zero will be canceled.*

In the case that part of a bonus is invested (a trade is opened) at the time of deposit, the cap will be reduced but may be increased up to its previous amount in the case there will be a positive return on expiration.

* Bonus cancellation: A bonus will be canceled in case it has been totally lost (cap=0, no open trades older than deposit) and a deposit has been made.

Withdrawal limitation

A user can withdraw the total of the net deposits and released bonus amount, minus net loss, made after the last available bonus has been given (bonus that has not reached target volume).

(deposit + released bonus – withdraw – net loss)

Any withdrawalable amount higher than the amount the user deposited after a certain bonus will cause bonus cancellation and may cause a cancellation of the net profit made after the bonus was given, this is dependent on the bonus type.

Target Volume

The target volume is the volume the user needs to trade in order to release the bonus or any related profit/deposit, and remove any restrictions from the bonus. Volume is valid only when a trade reaches the expiry time. For example, Sellback or Risk Free Trades are not being calculated towards trading volume in that matter. In case user has more than one bonus, volume will count towards the active bonus. Once a bonus has reached its target, it will automatically change its status and release the bonus amount to cash.

Active Bonus

The active bonus is the bonus being used for trading and the bonus in which the trading volume is being counted towards first. In other words, it is the first bonus in the list, in matter of target volume and trading power. The default active bonus is the oldest bonus that has not reached the target volume. The user can control and change the specific bonus he wishes to accumulate volume to. Once an active bonus has reached its target volume or has been canceled, the active bonus will be the default bonus again (oldest).

Bonus types

Pending Bonus

The pending bonus allows the client full access to their available cash in the balance at all times. It is not restrictive. The pending bonus is simply released as real money into the balance to use or to take, once the client trades the necessary volume. This way it is an incentive to keep trading and a rewarding bonus for doing just that, trading.

What is a pending bonus?

A pending bonus is an amount of bonus money that is added into a client account. The bonus is not restrictive. The pending bonus is simply released as real money into the balance to use or to take, once the client trades the necessary volume.

As you can see in the example above, the account balance now shows $5,453 with a $1,000 bonus pending. As the bonus is still pending until the right volume has been traded, the Available Cash is $5,453.

How do you know your trading volume?

Once a pending bonus is added to a client account, a volume bar is automatically added into the client account. This volume bar calculates each trade made by the client, whilst also showing how much remaining trading volume is needed to be made until the bonus can be released. At any time, the client can see how much trading has been accomplished and how much more is needed to release the bonus.

Back to the example, you can see the client has traded $3,750 and has reached a trading volume of 25% shown in the volume bar. In this example, the user still needs to trade a volume of $11,250.

As indicated by the volume bar, the client has now traded the full volume to release the pending bonus.

Once the pending bonus is manually released in the back office, $1000 will be added to the balance as available cash.

Required Trading Volume

Pending bonus feature requires the user to trade a certain volume before the bonus is released as cash into the account balance. The volume required will be calculated according to the amount of bonus given. This feature allows you to offer competitive bonuses. Please see the calculation for required volume per bonus amount below:

 Up to 50% bonus – (deposit amount + bonus amount) x 30

 51-100% bonus – (deposit amount + bonus amount) x 30

 101-200% bonus – (deposit amount + bonus amount) x 30

 Above 200% bonus – (deposit amount + bonus amount) x 35

What is the advantage?

Other Binary Option trading platforms offer large cash bonuses. However, once received, client funds are not available to withdraw and are restricted until volume demands are met. This can be a major problem for anyone needing access to their extra income stream in a hurry!

Users receive a bonus that is designed to reward them for continued trading. It can be used as a safety net, as each trade made and completed will count towards releasing back real cash into the balance.

If your users would like to withdraw before trading the volume to release the bonus, their funds are available. Once bonus money has been released as real cash, they can continue trading or you are free to withdraw it. It is not suggested to promote bonus withdrawals.

 Smart Bonus

 Bonus can be used for trading

 Bonus cannot be withdrawn before the target volume has been reached

Deposit and profit can be withdrawn

In case of a withdrawal, the bonus will be cancelled but the profit will be kept

Profit Bonus

Bonus can be used for trading

The bonus and any profit made after the bonus has been given cannot be withdrawn before the target volume has been reached

Deposit can be withdrawn

In case of a withdrawal, the bonus and profit made after the bonus has been given will be cancelled

Balance Bonus

Bonus can be used for trading.

The bonus, all the balance prior to the bonus giving, including the related deposit, and any profit made after the bonus has been given, cannot be withdrawn before the target volume has been reached, whatsoever.

ChartOption reserves the right to change the terms and conditions without prior notice.

If you have any questions or concerns, please contact your account manager or email at: info@ChartOption.com

3 – COMPANY INFORMATION

Legal framework: Chartoption (“the Company”) is authorized and regulated by the Cyprus Securities and Exchange Commission (“CySEC”) as a Cyprus Investment Firm (“CIF”). The Company is entitled to offer the services and activities enlisted herein in this document, in accordance with the following legal requirements: Provision of Investment Services, the Exercise of Investment Activities, the Operation of Regulated Markets and Other Related Matters Law 144(I)/2007, as periodically amended (“the Law”).

The Company’s CIF license number is 241/14. 
The Company is registered in Cyprus under the Companies Law, with registration number HE279568.
The Company’s registered office is at Grigori Afxentiou 13, Limassol  4003. 

Scope of Services:  According to its CIF License, the Company is entitled to offer the following Investment Services:

Reception and transmission of Orders in relation to one or more of the Financial Instruments enlisted below.  Execution of Orders on behalf of Clients.

Others Services : According to its CIF License, the Company may offer the following Ancillary Services:

Investment research and financial analysis or other forms of general recommendation relating to transactions in Financial Instruments

Safekeeping and administration of Financial Instruments for the account of Clients, including custodianship and related services such as cash/collateral management.

Granting credits or loans to an investor to allow him to carry out a transaction in one or more Financial Instruments where the Company is involved in the transaction.

Foreign exchange services where these services are connected to the provision of investment services.

Financial Instruments :Under its CIF license, the Company may offer the above investment services in relation to certain Financial Instruments, as defined in paragraph 2 of the Law:

Financial contracts for differences
Units in collective investment undertakings.
Transferable Securities.
Money-market instruments.

Options, futures, swaps, forward rate agreements and any other derivative contracts relating to securities, currencies, interest rates or yields, or other derivatives instruments, financial indices or financial measures which may be settled physically or in cash.

Options, futures, swaps, forwards and any other derivative contracts relating to commodities, that can be physically settled (not otherwise mentioned in the paragraph above and not being for commercial purposes), if they have the characteristics of other derivative financial instruments, with regard to whether, inter alia, cleared and settled through recognized clearing houses, or subject to regular margin calls.

Options, futures, swaps, and any other derivative contract relating to commodities that can be physically settled, provided that they are traded on a regulated market and/or a MTF.

Options, futures, swaps, forward rate agreements and any other derivative contracts relating to commodities that must be settled in cash or may be settled in cash at the option of one of the parties (otherwise than by reason of a default or other termination event).

Derivative instruments for the transfer of credit risk.

Options, futures, swaps, forward rate agreements and any other derivative contracts relating to climatic variables, freight rates, emission allowances or inflation rates or other official economic statistics that must be settled in cash or may be settled in cash at one party’s option (otherwise than by reason of a default or other termination event), as well as any other derivative contract relating to assets, rights, obligations, indices and measures not otherwise mentioned in this Part, which have the characteristics of other derivative financial instruments, with regard to whether, inter alia, traded on a regulated market or an MTF, cleared and settled through recognized clearing houses or subject to regular margin calls.

4 – CORPORATE GOVERNANCE

Chartoption is a leader company in the binary field as a result of hard work and a constant willing to improve its services. Our Company aims to give to each Client, the best trading experience, the best and accurate financial information, as available, and the adequate infrastructure to ensure his success.  Our goal is to always search new ways in order to provide the Client with the most relevant instruments to allow a successful transaction in binary options.

At Chartoption, we focus on the transparency of all our endeavors.  We aim to give to our traders the feeling of safety and peace of mind, when they are involved in financial activities. Our Company is willing to give each of our Clients the feeling that our services are accessible anytime.

For Chartoption, caring for our traders is the best way to enhance our brand name and strengthen our market share. Therefore, our website contains a specific section explaining in details who we are, and how we can help you to increase your revenue and be a successful trader in binary options.

Hereinafter some of the subjects described in detail in the Company website:

Press Release – Remain up-to-date with all things occurring at Chartoption! Our Press Release segments provide you all the news about our company and also the new improvements for your satisfaction.

Legal Terms & Conditions – Be responsible and read our legal terms and conditions carefully. It is an important habit to be periodically informed about the regulations applying to our investments.

About Us – Be informed about the Company as being the largest binary options broker worldwide, and reassure yourself that your investments are in the most experienced and reliable hands.

Contact Us – Did you know that Chartoption is available for you, worldwide? You can choose out of 13 international phone numbers and contact the nearest Chartoption’s representative.

Bonus Terms & Conditions – Chartoption offers you some amazing bonuses therefore, you should check out how to beneficiate of such bonuses and try to achieve them.

Security and Privacy – This is essential information that provides you the guaranty that Chartoption is engaged to protect the safety of your transactions.

Remember, we are always here to answer to your questions and assist you:  we are concerned by assisting you and avoid any doubts.

Remain informed by visiting the Chartoption amazing platform and top-notch services!

Don’t stop here! Our website is rich with valuable information and tutorials to ensure that you will become a pro trader.

5 – COMPLAINTS PROCEDURE FOR CLIENTS

Chartoption has adopted the following Complaints Procedure in order to ensure a fair and quick process for handling complaints that may arise.

Submission process

– Write and address your complaint to the Compliance Officer of Chartoption who is authorized to handle and investigate.

– Please use the Complaints Form attached hereafter as following:

1.    Send by post or deliver in person the Complaints Form at the following address: Zavos City Center , Grigori Afxentiou 13&15 IDE Ioannou Court, Office 105, Mesa Yeitonia, Limassol CY-4003 Cyprus.

2.    Electronic delivery of the complaint form  at the following email addresses: info@Chartoption.com.

3.    Complaint  process : After receipt of your complaint, we will review it carefully.

Further clarifications and information relating to your complaint may be required. Your cooperation is important.

Final or partial answer (e.g. if further information is required) to your complaint shall be provided within one (1) calendar day from its receipt. When a partial answer is sent, we shall inform you about the investigation progress.

Notwithstanding the existence and/or use of such complaint procedure, legal procedures remain unaffected. In addition, you are entitled to submit your complaint to the Financial Ombudsman services of Cyprus.

To download the complaint form, please click here

6 – INVESTOR COMPENSATION FUND

General: Chartoption (hereinafter, the “Company”) is a member of the Investor Compensation Fund (“ICF”) for the Clients of Cyprus Investment Firms (“CIFs”), in accordance with the following regulations: the Provision of Investment Services, the Exercise of Investment Activities, the Operation of Regulated Markets and Other Related Matters Law 144(I)/2007, as periodically amended from time to time (“the Law”).

Scope of Services : The scope of services of the Company is: the investment services of (i) Reception and Transmission of Orders in relation to one or more Financial Instruments, (ii) Execution of Orders on behalf of Clients and (iii) Safekeeping and administration of financial instruments, including custodianship and related services offered by the Company.

Purpose: The purpose of the ICF is to secure any claims of the covered Clients against members of the ICF. The main essence of the ICF is to compensate covered Clients for any claims arising from the failure of a member of the ICF to fulfil its obligations towards its Clients, despite whether that obligation arises from the legislation, the Client agreement or from any breach on the part of the member of the ICF.

Category of Clients : The ICF covers Retail Clients of the Company. It does not cover Professional Clients and Eligible Counterparties. For more details see paragraph below.

Non-Covered Clients:  The ICF shall pay no compensation to individuals against whom criminal proceedings under the provisions of the Prevention and Suppression of the Legalization of Proceeds from Criminal Activities Law of 2007, as amended or replaced, are pending.

In accordance with the Applicable Regulations, the ICF does not compensate the following investor categories:

(a)    The following categories of institutional and professional investors:

Investment Firms (IFs).
Legal entities associated with the Company and, in general, belonging to the same group of companies.
Banks.
Cooperative credit institutions.
Insurance companies.
Collective investment organizations in transferable securities and their management companies.
Social insurance institutions and funds.
Investors characterized by the Company as professionals, upon their request.

(b)   States and supranational organizations.

(c)    Central, federal, confederate, regional and local administrative authorities.

(d)   Enterprises associated with the Company.

(e)    Managerial and administration staff of the Company.

(f)    Shareholders of the Company whose participation directly or indirectly in the capital of the Company amounts to at least 5% of its share capital, or its partners who are personally liable for the obligations of the Company, as well as persons responsible for the carrying out of the financial audit of the Company as provided by the Law, such as qualified auditors.

(g)   Investors having affairs connected with the Company and, in general, group of companies to which the Company belongs, positions or duties corresponding to the ones listed in sub-paragraphs (e) and (f).

(h)   Second-degree relatives and spouses of the persons listed in sub-paragraphs (e), (f) and (g) of this paragraph as well as third parties acting for the account of these persons.

(i)     Investors-Clients of the Company responsible of Company’s financial difficulties or having contributed to the worsening of its financial situation /profited from these facts. [Exception is made to investors convicted of a criminal offence pursuant to the Prevention and Suppression of Money Laundering Activities Law of 2007, as amended or replaced].

(j)     Company investor that, due to its size, is not allowed to draw a summary balance sheet in accordance with the Companies Law or a corresponding law of a Member State of the European Union.

In the cases of sub-paragraphs (e), (f), (g) and (g) of paragraph above., the ICF suspends the payment of compensation -informing the interested parties accordingly- until the final decision (whether such cases apply or not).

Compensation Payment Process; The ICF compensates the covered Clients for claims arising from the covered services provided by the Company, when failure by the Company to fulfill its obligations has been ascertained.

Definition of a failure by the Company to fulfill its obligations:

(a)    To refund to covered Client fund relating to covered services and such Client requested the Company to refund; or  (b)   To return to the covered Clients its financial instruments managed by the Company.

The ICF initiates the compensation payment process in one of the following situations:

(a)    The Cyprus Securities and Exchange Commission (CySEC) has determined by resolution that that the Company is unable to meet its duties as arise from its Clients’ claims. Client claims shall be connected with the investment services it has provided. This inability shall be directly related to the financial circumstances (no realistic foreseeable prospect of improvement in the near future). The CySEC shall issue its decision on the beginning of the compensation payment procedure by the ICF and shall publish it in the Official Gazette of the Republic of Cyprus as well as on its website.

CySEC can issue such decision when at last one of the following preconditions is fulfilled:

(i)     The Company submits to the ICF or to CySEC a written statement declaring its failure to fulfil its obligations towards its Clients; or (ii)  The Company files an application for liquidation in accordance with the provisions of Part V of the Companies Law of Cyprus; or (iii)  CySEC has revoked or suspended the Company’s authorization to provide investment services and confirms that the Company is not expected to be in a position to fulfil its obligations toward its Clients in the near future, for reasons which do not concern a temporary lack of liquidity which can be dealt with immediately.

(b)   A judicial authority has, on reasonable grounds directly related to the financial circumstances of the Company, issued a ruling which suspend the investors’ ability to act against it.

Upon issuance of a decision to initiate the compensation payment process by a Court or by CySEC, the ICF shall publish, in at least three (3) newspapers of national coverage, an invitation to the covered Clients to make their claims against the Company. The invitation outlines the procedure for submission of the relevant compensation applications, including the deadline for submission and the content of such applications.

The compensation applications of covered Clients with which they make their claims against the Company, are submitted to the ICF in writing and must include:

(i) The name of the claimant-Client;(ii) The address, telephone and fax numbers as well as any email address of the claimant-Client; (iii) The Client code that the claimant-Client had with the Company; (iv) The particulars of the covered services agreement between the ICF and the claimant-Client; (v) The type and amount of the alleged claims of the claimant-Client; (vi)  The exposition of the particulars from which the alleged claims of the claimant-Client and their amount are delivered; (vii) Any other information the ICF might or will request.

Upon submission of the compensation applications, the Administrative Committee of the ICF shall control especially if:

(i)  The claimant-Client falls within the category of covered Clients; (ii) The application was timely submitted; (iii) The claimant-Client is not convicted of a criminal offence pursuant to the Prevention and Suppression of Money Laundering Activities Law of 2007, as amended or replaced; (iv)The conditions for the valid submission of compensation applications are fulfilled.

The Administrative Committee rejects the compensation application in case the claimant-Client does not fulfill the conditions referred, or if at the Administrative Committee’s discretion, at least one of the following reasons exists:

(i) The claimant-Client used fraudulent means in order to secure the payment of compensation by the ICF, especially if it submitted false evidence with full knowledge of the fact; (ii)  The damage suffered by the claimant substantially derived from concurrent negligence or offence on its behalf in relation to the damage it suffered and to its underlying cause.

Upon completion of the valuation, the ICF:

(i)  Issues minutes listing the Clients of the Company which are compensation beneficiaries along with the amount of money each one of them is entitled to receive, and, communicates it to CySEC and the Company, within five (5) working days from its issue; and (ii)  Communicates to each affected Client, no later than fifteen (15) days from the issue of the aforementioned minutes, an answer determining the total compensation amount this Client is entitled to receive.

Amount of Compensation: The amount of compensation payable to each covered Client is calculated in accordance with the legal and contractual terms governing the relation of the covered Client with the Company, subject to the rules of setoff as applied for the calculation of the claims.

The calculation of the payable compensation derives from the sum of total established claims of the covered Client against the Company, arising from all covered services provided by the Company and regardless of the number of accounts the customer is a beneficiary of, the currency and place of provision of these services.

The total payable compensation to each covered Client of the Company may not exceed the amount of twenty thousand Euros (EUR 20,000), irrespective of the number of accounts held, currency and place of offering the investment service.

In case where beneficiaries of a joint account of the Company are in their majority covered Clients:

(a)    the maximum amount payable to all co-beneficiaries of the account comes up to the amount of twenty thousand Euros (EUR 20,000); and (b)   the compensation is fixed on the whole for all co-beneficiaries of the joint account and is divided amongst them, in the way determined in the agreement between the co-beneficiaries and the Company; otherwise, in the absence of such agreement, it is divided equally among them.

7 – PRIVACY POLICY

Last Updated: July 22, 2015

Chartoption Company fully respects your right to privacy. In order for us to carry out our services to you it will be necessary for us to use your personal information (“information”). Please read our Privacy Policy carefully before continuing with this website. Your continued use of this website indicates your agreement to the Privacy Policy and any changes to it. As we may change our Privacy Policy from time to time, please check this page regularly.

This Policy is an integral part of the Site’s and Service’s General Terms and Conditions (the “Terms and Conditions”).

A. Information Collection

What Information Does Chartoption Collect?

We collect two types of data and information from you:
Personnel information: In the course of using the Service, we will ask you to provide us with certain personally identifiable information that can be used to contact or identify you and administer your account (“Personal Information”), as well as enabling you to access to certain restricted parts of the Site and the Service.
Personal Information may include, but is not limited to: your name, mailing address, email address, telephone number, credit card and bank account details.
We also maintain information as a result of your trading activity as well as monitoring and recording all or part of our communications with you. We may also present links on the Site in a format that enables us to keep track of whether these links have been followed.
Non-Personal Information – we retain some non-personally identifiable information (“Non-Personal Information”), such as your approximate geo-location, your web request, browser type, browser language, web pages you visit before or after visiting our Website or using the App, URLs, platform type, click numbers, landing pages, viewed pages and the order of those pages and time spent on pages. This information is collected and retained for security reasons and so that we can audit and statistically track usage, audit our affiliates, and calculate payments to third parties.
“Cookies” – Non-Personal Information is collected, inter alia, through the use of cookies, so when accessing or using the Website, we may use one or more cookies. Cookies are small text files, placed on a user’s device, which enable a website to remember user preferences. Detailed information about cookies and how we use them on the Website and other websites implementing our web tools may be found in our Cookie Policy, which also describes how you can turn off cookies or control them.
We use Google Analytics on the Site, a web analytics service provided by Google, Inc. (“Google”). Google Analytics is used to help us obtain data regarding use of the Site. The information generated by the cookie about your use of the Site (including your IP address) may be transmitted to and stored by Google on servers in the United States. Google will use this information for evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full website functionality. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Third Party Sites

This Policy applies only to the Service. We do not exercise control over other websites, applications or services that provide information, or over banners, other advertisements or links from within the Site or the Service. These other sites, applications or services may place their own cookies or other files on your computer, collect data or solicit personal information from you subject to such third party’s privacy policy.

We encourage you to read the privacy policies and other terms of such third parties’ websites, applications or services before accessing or using them.

B. Use of Information

The information that we will use will depend upon the information that you give to us and the information that is necessary to collate in order to carry out our services for you. In all circumstances the information will be adequate, relevant and not excessive and will be processed in line with your rights. We do not collect any personally identifiable information from users of our ‘public’ area of our website. All we do is to gather information on the numbers of visitors to certain areas and the manner in which the website is navigated. However, in order to effectively operate the client login area of the website we may ask for personal information about yourself, and this will be processed in accordance with this Privacy Policy.

The collection and processing of Personal Information is aimed at providing you with services offered by the Website, to send you marketing offers on products or services we think may be relevant to you, and to fulfill other purposes as provided in this privacy policy. The Company will store this data as long as we believe it to be necessary and appropriate in order to provide and manage our services.

C. Right of Access, Rectification, Cancellation and Objection

You have the right to access, correct, update or object to the use of your Personal Information by making a written request to us, using our Contact Us page. Your requests will be dealt with in a prompt and professional manner.

D. Security and Confidentiality

The Company treats your Personal Information in strict confidentiality, and the server in which this data is to be stored includes the necessary industry-standard security measures to prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access. However, we cannot completely guarantee the security of your information, which might be accessed, disclosed, modified, or destroyed, and it should be emphasized that you share this information at your own risk.

E. Compliance with Laws and Law Enforcement:

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable.

F. Business Transfers:

We may sell, transfer or otherwise share some or all of our assets, including among others your Personal Information and Log Data, in connection with a merger, acquisition, reorganization or sale of all or substantially all of our shares or assets, or in the event of our bankruptcy.

Moreover, we may post additional ancillary privacy notices regarding specific services.

If you receive an e-mail asking you to update your Personal Information, do not reply and please contact us at info@Chartoption.com.

G. International Processing or Transfer

Your information may be processed, maintained or transferred outside of your state of residence, where the privacy laws may not be as protective as those in your jurisdiction.

H. Contacting Us

If you have any concerns or questions about this Policy, please contact us at info@Chartoption.com.

8 – RISK DISCLOSURE AND WARNINGS NOTICE

This risk disclosure and warning notice is provided to each client or prospective client (Hereinafter, the “Client”) in accordance with the following regulations: the Provision of Investment Services, the Exercise of Investment Activities, the Operation of Regulated Markets and Other Related Matters Law 144(I)/2007, as periodically amended (“the Law”).

The following risk disclosure and warning section shall be read carefully by the Client, before applying to the Chartoption Company for a trading account and before any financial transaction.

However, this document does not disclose or explain all of the risks and other significant aspects involved in dealing in Binary Options. The following section aims only to explain in general terms, the nature of the risks involved when dealing in Binary Options on a fair and non-misleading basis.

What are the risks?

Trading in Binary Options is VERY SPECULATIVE AND HIGHLY RISKY and so, not suitable for the general public but only for those investors who:
(a) Understand and are willing to assume the economic, legal and other risks involved in doing a transaction in binary options (Hereinafter, a “Transaction”).
(b) Take into account their personal financial situation, financial resources, life style and obligations and therefore, are able to assume the possible loss of their entire investment.
(c) Have the knowledge to understand Binary Options trading and the underlying assets and markets.

The Company will not provide the Client with any advice relating to Binary Options, the underlying assets and markets or make investment recommendations of any kind. Therefore, if the Client does not understand the risks involved, he should priory be advised and consult an independent financial counsel. If the Client still does not understand the risks involved in trading in Binary Options, he should not trade at all.

Binary Options are derivative financial instruments deriving their value from the prices of the underlying assets/markets in which they refer to (for example currency, equity indices, stocks, metals, indices futures, forwards etc.). Although the prices at which the Company trades are set by an algorithm developed by the Company, the prices are derived from the underlying assets /market.

The Client shall understand the risks associated with trading in the relevant underlying asset/ market because fluctuations in the price of the underlying asset/ market will affect the profitability of his transaction.

Here is a non-exhaustive list of the existing risks:

Volatility: movements in the price of underlying assets/ markets can be volatile and unpredictable. This will have a direct impact on the Clients profits and losses. Understanding the volatility of an underlying market will help the Client to understand how to trade and how much he is ready to lose.

Market liquidity: The prices of Binary Options will be influenced by, among other things, modification of the supply and demand, governmental, agricultural, and commercial and trade programs policies, national and international political and economic events. Consequently, the prevailing psychological characteristics of the relevant market place and some of the Binary Options’ underlying assets may not become immediately liquid as a result of the reduce of the demand for the underlying asset. Therefore, market conditions can change significantly in a very short period of time and hence, under certain market conditions. Client’s Order is not executed and consequently losses are incurred.

Due to movements and/or conditions occurring at any moment of the day, (weekend, in the beginning of week or intra-day) as a consequence of significant macroeconomic figures, economic or political news, and currency markets can suddenly open with price levels substantially different from previous prices.

Market swings: swing is a sudden shift in the price of an underlying asset price from one level to another. Various factors can lead to gapping (for example, economic events or market announcements) and gapping can occur both when the underlying market is open and when it is closed. When these factors occur while the underlying market is closed, the price of the underlying market when it reopens (and therefore our derived price) can be markedly different from the closing price, with no opportunity to close your transaction in-between. ‘Gapping’ can result in a significant loss (or profit).

The Client has no rights or obligations in respect of the underlying instruments or assets relating to the Binary Options he is trading.

Binary Options offered by the Company are not listed and/or traded on any regulated exchange. The prices and other conditions are set by the Company, and the calculation of the price to be paid (or the payout to be received) at the time the contract is purchased or sold, will be based on the Company’s best estimate of underlying market prices and the expected level of interest rates, taking into account volatilities and other market conditions during the life of the contract.

The prices and other conditions are based on complex arithmetic calculations.

Binary options trading can only be settled in cash and there is no delivery of the underlying asset.

Need to know:

Before trading, the Client shall obtain the details of all the taxes he is in charge of.

The Provision of Services by the Company is subject to charges, and/or taxes, as detailed in the Company’s website. It is the Client’s responsibility to check periodically and be updated of any changes occurring to charge amounts or nature.

There is no guarantee that no tax and/or any other duty are to be paid. There is a risk inherent to Binary Options trading that some tax and/or any other duty shall apply to a transaction. (For example:  legislation or Client personal circumstances). The Client is responsible for any taxes and/or any other duty which may accrue in respect of his trades.

Company’s prices are set by the Company and may be different from prices reported elsewhere. The Company’s trading prices are the ones at which the Company is willing to sell Binary Options to its Clients at the point of sale. As such, they may not directly correspond to real time market levels.

What are third party’s risks?

The Company may transfer the money received from a Client to a third party (e.g. a bank or broker) for hold or control, in order to make a transaction through or with such third party. The Company has no responsibility for any act or omission of this third party. The Company has the right to withhold Client’s money on the Client’s behalf outside the EEA. The legal and regulatory regime applying to any such bank or person will be different from that of Cyprus and in the event of the insolvency or any other similar proceedings in relation to that bank or person, the Client’s money may be treated differently from the treatment which would apply if the money was held with a bank in an account in Cyprus. The Company will have no liability with regard to such insolvency, acts or omissions of any third party referred to in this paragraph.

The Company is allowed to transfer Client’s money to a third party who may have a security interest, lien or any other right of set-off in relation to that money.

A Bank or Broker dealing with the Company may have interests contrary to the Client’s Interests.

In the event of the insolvency or any other similar proceedings in relation to that third party, the Company may only have an unsecured claim against the third party on behalf of the Client, and the Client will be exposed to the risk that the money received by the Company from the third party is insufficient to satisfy the claims of the Client in respect of the relevant account. The Company shall have no liability or responsibility for such losses.

Insolvency

The Company’s insolvency or default, may lead to positions being liquidated or closed out, without the Client’s consent.

Technical Risks:

The Client -not the Company- shall be solely responsible for the risks of financial losses caused by failure, malfunction, interruption, disconnection or malicious actions of information, communication, electronic or other systems.

If the Client undertakes transactions on an electronic system, he will be exposed to risks associated with the system including the failure of hardware, software, servers, communication lines and internet failure. The result of any such failure may be that his Order is either not executed according to his instructions or it is not executed at all. The Company shall have no liability in the case of such a failure.

The Company has no responsibility if unauthorized third persons have access to information, including electronic addresses, electronic communication and personal data, access data when the above are transmitted between the Company or any other party, using the internet or other network communication facilities, telephone, or any other electronic means.

The Client acknowledges that the unencrypted information transmitted by e-mail is not protected from any unauthorized access.

At time of excessive deal flow the Client may have some difficulties to be connected over the phone or the Company’s trading platform(s)/system(s), especially in fast Market (for example, when key macroeconomic indicators are released).

The Client acknowledges that the internet may be subject to events which may affect his access to the Company’s website and/or the Company’s trading platform(s)/system(s), including but not limited to interruptions or transmission blackouts, software and hardware failure, internet disconnection, public electricity network failures or hacker attacks. The Company is not responsible for any damages or losses resulting from such events which are beyond its control or for any other losses, costs, liabilities, or expenses (including, without limitation, loss of profit) which may result from the Client’s inability to access the Company’s Website and/or Trading System or delay or failure in sending Orders or Transactions.

The Client is aware that when trading in an electronic platform he assumes risk of financial loss which may be a consequence of among other things:

Failure of Client’s devices, software and poor quality of connection.
The Company’s or Client’s hardware or software failure, malfunction or misuse.
Improper work of Client’s equipment.
Wrong setting of Client’s Terminal.
Delayed updates of Client’s Terminal.

In connection with the use of computer equipment and data and voice communication networks, the Client in charge of the following risks among other risks and in such cases, the Company has no liability of any resulting loss:

Power cut of the equipment on the side of the Client or the provider, or communication operator (including voice communication) that serves the Client.

Physical damage (or destruction) of the communication channels used to link the Client and provider (communication operator), provider, and the trading or information server of the Client.
Outage (unacceptably low quality) of communication via the channels used by the Client, or the channels used by the provider, or communication operator (including voice communication) that are used by the Client.
Wrong or inconsistent with requirements settings of the Client Terminal.
Untimely update of the Client Terminal.
When carrying out transactions via the telephone (land or cell phone lines) voice communication, the Client runs the risk of problematic dialing, when trying to reach an employee of the broker service department of the Company due to communication quality issues and communication channel loads.
The use of communication channels, hardware and software, generate the risk of non-reception of a message (including text messages) by the Client from the Company.
Trading over the phone might be impeded by overload of connection.
Malfunction or non-operability of the trading system (platform), which also includes the Client Terminal.
Outage (unacceptably low quality) of communication via the channels used by the Company, in particular physical damage (destruction) of the communication channels by third parties.

What kind of trading Platform?

The Client acknowledges that only one Instruction is allowed to be in the queue at one time. Once the Client has sent an Instruction, any further Instructions sent by the Client are ignored and the “Orders is locked” message appears until the first Instruction is executed.

The Client acknowledges that the only reliable source of Quotes Flow information is that of the live Server’s Quotes Base. Quotes Base in the Client Terminal is not a reliable source of Quotes Flow information because the connection between the Client Terminal and the Server may be disrupted at some point and some of the Quotes simply may not reach the Client Terminal.

The Client acknowledges that when the Client closes the Order placing/ deleting window or the position opening/closing window, the Instruction, which has been sent to the Server, shall not be cancelled.

Force Majeure

In case of Force Majeure Events the Client shall accept the risk of financial loss.

Investor Compensation Fund

The Company participates in the Investor Compensation Fund for clients of Investment Firms regulated in the Republic of Cyprus. Certain clients will be entitled to compensation under the Investor Compensation Fund where the Company fails. Compensation shall not exceed twenty thousand Euro (EUR 20.000) for each entitled Client. For more details please refer to the “Investor Compensation Fund” found on our website.

Warning

The Company will not advise the Client about the merits of a particular Transaction or give him any form of investment advice and the Client acknowledges that the Services do not include the provision of investment advice in Binary Options or the Underlying Markets. The Client on his own will enter into Transactions and take relevant decisions based on his own judgment. By asking the Company to enter into any Transaction, the Client represents that he has been solely responsible for making his own independent appraisal and investigation of the risks of the Transaction. He represents that he has sufficient knowledge, market sophistication, professional advice and experience to make his own evaluation of the merits and risks of any Transaction. The Company gives no warranty as to the suitability of the products traded under this Agreement and assumes no fiduciary duty in its relations with the Client.

The Company has no obligation to provide the Client with any legal, tax or other advice relating to any Transaction. The Client should priory obtain an independent expert advice if he has any doubt as to whether he may incur any tax liabilities. The Client is hereby warned that tax laws are subject to change from time to time.

The Company may, from time to time and at its discretion, provide the Client (or in newsletters which it may post on its Website or provide to subscribers via its Website or the Trading Platform or otherwise) with information, recommendations, news, market commentary or other information but such general information cannot be assimilated to a service due by the Company. Nevertheless:

(a)     The Company will not be responsible for such information;

(b)     The Company gives no representation, warranty or guarantee as to the accuracy, correctness or completeness of such information or as to the tax or legal consequences of any related Transaction;

(c)     This information is provided solely to enable the Client to make his own investment decisions and cannot be assimilated to an investment advice or unsolicited financial promotions to the Client;

(d)    If the document contains a restriction on the person or category of persons for whom that document is intended or to whom it is distributed, the Client agrees that he will not pass it on to any such person or category of persons;

(e)     The Client accepts that prior to dispatch, the Company may have acted upon it itself to make use of the information on which it is based. The Company does not make any representations as to the time of receipt by the Client and cannot guarantee that he will receive such information at the same time as other clients.

Market commentary, news, or other information provided or made available by the Company are subject to change and may be withdrawn at any time without notice.

No Profit guaranty

The Company or any of its representatives does not provide any guarantee of profit or absence of losses, when trading in Binary Options.

The Client is aware of the risks inherent in trading in Binary Options and is financially able to bear such risks, despite any losses incurred.

9 – CONFLICT OF INTEREST POLICY

This Conflicts of Interest Policy (“the Policy”) is provided to the Client or prospective Client (“the “Client”) in accordance with the following regulations: Provision of Investment Services, the Exercise of Investment Activities, the Operation of Regulated Markets and Other Related Matters Law 144(I)/2007, as periodically amended (“the Law”).

We are required by the Law to maintain a conflicts of interest policy identifying the circumstances that constitute or may give rise to a conflict of interest entailing a material risk of damage to the interests of one or more clients, and specifying the procedures that we follow and measures that we adopt in order to manage such conflicts. All financial services firms will face areas of potential conflicts of interest, the nature of these depending upon the nature of a firm’s business model. We conduct a full service investment management, corporate finance and brokerage business. This section contains a description, in summary form, of our conflicts of interest policy. Clients requiring further information should contact us.

Scope : The Policy applies to all its directors, employees, any persons directly or indirectly linked to the Company (hereinafter called “Related Persons”) and refers to all interactions with all Clients.

Identification: Where any firm acts for more than one client, there is the possibility of a conflict of interest. For example, when we recommend a transaction to you or enter into a transaction for you, we (or a Person connected with us) may face conflicts where we are:

(i) Carrying out your Order by matching it with that of another client;

(ii) Carrying out comparable Orders given simultaneously by different clients;

(iii) Allocating Investments, where you are a discretionary managed client or your Orders are aggregated with those of other clients but full allocations are not possible;

(iv)  Acting as agent for a company issuing new securities to you; or

(v) Issuing research where we also act for the company the subject of the research

Conflicts may also exist between the interests of a firm, including Persons connected with it, and the interests of clients. For example, when we give you investment advice or arrange a discretionary transaction on your behalf, we (or a Person connected with us) may have an interest, relationship or arrangement that is material in relation to the Investment, transaction or service concerned. We (or a Person connected with us) could be dealing as principal for our (or the connected Person’s) own account by selling the Investment concerned to you or buying it from you. We (or a Person connected with us) may be the trustee or operator (or an adviser to the trustee or operator) of a collective investment scheme or other in which you are advised to invest, or in which discretionary transactions are arranged for you if you are a discretionary client. We may receive remuneration or benefits from third party product providers or issuers of shares in respect of transactions carried out on your behalf.

To identify different types of conflict that might arise in the course of providing its Services, and whose existence may be in conflict with Clients’ interests, the Company shall control if the Company itself or a Related Person, or a person directly or indirectly linked by control to the Company, is in any of the following situations, as a result of providing investment services or otherwise:

(a)    The Company or a Related Person is likely to make a financial gain or avoid a financial loss at the expense of a Client.

(b)   The Company or a Related Person receives or will receive from a person other than the Client an inducement in relation to a service provided to the Client, in the form of monies, goods or services, other than the standard commission or fee for that service.

(c)    The Company or a Related Person has an interest in the outcome of a service provided to the Client or of a transaction carried out for the Client, which is distinct from the Client’s interest in that outcome.

(d)   The Company or a Related Person has a financial or other incentive to prefer the interest of another Client or group of Clients over the interests of the Client.

(e)    The Company or a Related Person carries on the same business as the Client.

Management of Conflict of Interest: In general, the procedures and controls that the Company follows to manage the identified conflicts of interest include the following measures (list is not exhaustive):

(a)      Internal controls to be settled and to be appropriate.

(b)     Prevention or control of the exchange of information between Related Persons engaged in activities involving a risk of a conflict of interest, when such exchange of that information may violate the interests of one or more Clients.

(c)      Proceed with a separate supervision of Related Persons involved in conflicting services to Clients, or representing different interests that may conflict, including those of the Company.

(d)     Preventing any person from exercising inappropriate influence impacting the way a Related Person carries out investment services.

(e)      Prevention or control of the involvement of a Related Person in separate investment services where such involvement may impair the proper management of conflicts of interest.

(f)      Establishment of a policy to limit the conflict of interest arising from receipt/providing of inducements.

(g)     Establishment of Chinese walls restricting the flow of internal confidential information of the Company, and division of departments.

(h)     Procedures governing access to electronic data.

(i)       Segregation of duties that may give rise to conflicts of interest if carried on by the same individual.

(j)       Personal account to Related Persons.

(k)     Establishment of in-house Compliance Department to monitor and report on the above to the Company’s Board of Directors.

(l)       Prior approval of the Company’s board of directors in order to allow officers and employees of the Company having external business interests in contradiction with the Company’s interest.

(m)   A “need-to-know” policy governing the dissemination of confidential or inside information within the Company.

(n)     Appointment of Internal Auditor to ensure that appropriate systems and controls are maintained and reported to the Company’s Board of Directors.

(o)     Establishment of the “four- eyes” principle in supervising the Company’s activities.

Disclosure of Information: If during the course of a business relationship with a Client or group of Clients, the organizational or administrative arrangements/measures in place are not sufficient to avoid or manage a conflict of interest relating to that Client or group of Clients, the Company will disclose the conflict of interest before undertaking further business relation with the Client or group of Clients.

Client’s Consent : By entering into a Client Agreement with the Company for the provision of Investment Services, the Client acknowledges to be bound by this Policy. Moreover, the Client consents to and authorizes the Company to deal with the Client in any manner which the Company considers appropriate, notwithstanding any conflict of interest or the existence of any material interest in a Transaction, without prior reference to the Client.

In the event that the Company is unable to deal with a conflict of interest situation it shall revert to the Client.

Amendment of the Policy and Additional Information: The Company reserves the right to review and/or amend its Policy and arrangements whenever it deems this appropriate without notice to the Client.

Should you require any further information and/or have any questions about conflicts of interest please direct your request and/or questions to info@Chartoption.com.

10 – TERMS AND CONDITIONS FOR THE USE OF THE WEBSITE

This Conflicts of Interest Policy (“the Policy”) is provided to the Client or prospective Client (“the “Client”) in accordance with the following regulations: Provision of Investment Services, the Exercise of Investment Activities, the Operation of Regulated Markets and Other Related Matters Law 144(I)/2007, as periodically amended (“the Law”).

We are required by the Law to maintain a conflicts of interest policy identifying the circumstances that constitute or may give rise to a conflict of interest entailing a material risk of damage to the interests of one or more clients, and specifying the procedures that we follow and measures that we adopt in order to manage such conflicts. All financial services firms will face areas of potential conflicts of interest, the nature of these depending upon the nature of a firm’s business model. We conduct a full service investment management, corporate finance and brokerage business. This section contains a description, in summary form, of our conflicts of interest policy. Clients requiring further information should contact us.

Scope : The Policy applies to all its directors, employees, any persons directly or indirectly linked to the Company (hereinafter called “Related Persons”) and refers to all interactions with all Clients.

Identification: Where any firm acts for more than one client, there is the possibility of a conflict of interest. For example, when we recommend a transaction to you or enter into a transaction for you, we (or a Person connected with us) may face conflicts where we are:

(i) Carrying out your Order by matching it with that of another client;

(ii) Carrying out comparable Orders given simultaneously by different clients;

(iii) Allocating Investments, where you are a discretionary managed client or your Orders are aggregated with those of other clients but full allocations are not possible;

(iv)  Acting as agent for a company issuing new securities to you; or

(v) Issuing research where we also act for the company the subject of the research

Conflicts may also exist between the interests of a firm, including Persons connected with it, and the interests of clients. For example, when we give you investment advice or arrange a discretionary transaction on your behalf, we (or a Person connected with us) may have an interest, relationship or arrangement that is material in relation to the Investment, transaction or service concerned. We (or a Person connected with us) could be dealing as principal for our (or the connected Person’s) own account by selling the Investment concerned to you or buying it from you. We (or a Person connected with us) may be the trustee or operator (or an adviser to the trustee or operator) of a collective investment scheme or other in which you are advised to invest, or in which discretionary transactions are arranged for you if you are a discretionary client. We may receive remuneration or benefits from third party product providers or issuers of shares in respect of transactions carried out on your behalf.

To identify different types of conflict that might arise in the course of providing its Services, and whose existence may be in conflict with Clients’ interests, the Company shall control if the Company itself or a Related Person, or a person directly or indirectly linked by control to the Company, is in any of the following situations, as a result of providing investment services or otherwise:

(a)    The Company or a Related Person is likely to make a financial gain or avoid a financial loss at the expense of a Client.

(b)   The Company or a Related Person receives or will receive from a person other than the Client an inducement in relation to a service provided to the Client, in the form of monies, goods or services, other than the standard commission or fee for that service.

(c)    The Company or a Related Person has an interest in the outcome of a service provided to the Client or of a transaction carried out for the Client, which is distinct from the Client’s interest in that outcome.

(d)   The Company or a Related Person has a financial or other incentive to prefer the interest of another Client or group of Clients over the interests of the Client.

(e)    The Company or a Related Person carries on the same business as the Client.

Management of Conflict of Interest: In general, the procedures and controls that the Company follows to manage the identified conflicts of interest include the following measures (list is not exhaustive):

(a)      Internal controls to be settled and to be appropriate.

(b)     Prevention or control of the exchange of information between Related Persons engaged in activities involving a risk of a conflict of interest, when such exchange of that information may violate the interests of one or more Clients.

(c)      Proceed with a separate supervision of Related Persons involved in conflicting services to Clients, or representing different interests that may conflict, including those of the Company.

(d)     Preventing any person from exercising inappropriate influence impacting the way a Related Person carries out investment services.

(e)      Prevention or control of the involvement of a Related Person in separate investment services where such involvement may impair the proper management of conflicts of interest.

(f)      Establishment of a policy to limit the conflict of interest arising from receipt/providing of inducements.

(g)     Establishment of Chinese walls restricting the flow of internal confidential information of the Company, and division of departments.

(h)     Procedures governing access to electronic data.

(i)       Segregation of duties that may give rise to conflicts of interest if carried on by the same individual.

(j)       Personal account to Related Persons.

(k)     Establishment of in-house Compliance Department to monitor and report on the above to the Company’s Board of Directors.

(l)       Prior approval of the Company’s board of directors in order to allow officers and employees of the Company having external business interests in contradiction with the Company’s interest.

(m)   A “need-to-know” policy governing the dissemination of confidential or inside information within the Company.

(n)     Appointment of Internal Auditor to ensure that appropriate systems and controls are maintained and reported to the Company’s Board of Directors.

(o)     Establishment of the “four- eyes” principle in supervising the Company’s activities.

Disclosure of Information: If during the course of a business relationship with a Client or group of Clients, the organizational or administrative arrangements/measures in place are not sufficient to avoid or manage a conflict of interest relating to that Client or group of Clients, the Company will disclose the conflict of interest before undertaking further business relation with the Client or group of Clients.

Client’s Consent : By entering into a Client Agreement with the Company for the provision of Investment Services, the Client acknowledges to be bound by this Policy. Moreover, the Client consents to and authorizes the Company to deal with the Client in any manner which the Company considers appropriate, notwithstanding any conflict of interest or the existence of any material interest in a Transaction, without prior reference to the Client.

In the event that the Company is unable to deal with a conflict of interest situation it shall revert to the Client.

Amendment of the Policy and Additional Information: The Company reserves the right to review and/or amend its Policy and arrangements whenever it deems this appropriate without notice to the Client.

Should you require any further information and/or have any questions about conflicts of interest please direct your request and/or questions to info@Chartoption.com.

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