Terms and Conditions

Client Trading Agreement

1. INTRODUCTION

1.1. This Agreement determines the processing and execution of the Client’s trade orders.

1.2. This Agreement defines:

• The principles of opening / closing, placing, changing, deleting and executing orders;

• Actions of the Company in case of insufficient margin level in the Client's account to maintain open positions;

• Procedure for the settlement of disputes between the Client and the Company;

• Methods of exchanging information between the Client and the Company.

2. GENERAL PROVISIONS

2.1. The procedure for processing trade orders issued through the client terminal goes through the following steps:

• The client issues an order, which is being checked for correctness in the client terminal;

• The client terminal sends the order to the server;

• If there is a stable Internet connection between the client terminal and the server, the Client’s order is sent to the server and checked for correctness;

• The Client’s order, recognized as correct, is placed in the queue and sorted by time (the first order in the queue will be the first to be processed). In the “Order” window of the client terminal, the current processing status of the order “Order is accepted” is displayed. The company is not responsible for the delay in the execution of orders of any type under abnormal market conditions;

• When ready, the Company accepts the first order in the queue and proceeds with its processing. In the “Order” window of the client terminal, the current processing status of the Order “Order is in process” is displayed;

• The result of processing by the Company of a client’s order is sent to the server;

• The server sends the result of the Company's processing of the client’s order to the client terminal;

• If there is a stable Internet connection between the client terminal and the server, the client terminal receives the result of processing the order from the Company.

2.2. The client can cancel the sent order only if it has the status “Order is accepted”. To cancel, the Client must click the “Cancel order” button.

2.3. The Client does not have the right to cancel the sent order if it has already been received by the Company and has the status “Order is in process”.

2.4. A Client’s Order to open a position can be executed at a price that differs from the quote that the Client received in the client terminal during the last market snapshot in the following cases: a) if the current quote has changed since the last market snapshot; b) if the quotation from the last s market snapshot is applicable to a smaller volume of a trade operation than the volume of a client’s trade operation.

2.5. The time for executing a client’s order by the Company depends on the quality of the Internet connection between the client terminal and the server, as well as on market conditions.

2.6. The waiting time for each client order placed in the queue for processing is limited to 3 (three) minutes. If during this time the order was not received by the Company, then it is considered irrelevant and is automatically deleted.

2.7. In abnormal market conditions, the Company has the right to refuse to execute any orders.

2.8. The company has the right to reject the Client’s order, and the message “Off quotes”, “Not enough money” or “Trade is disabled” appears in the client terminal:

• at the time of opening trading on the market, if the Client sends an order before the first quotation is available at the trading platform;

• if the Free Margin of the Client is less than the Initial Margin;

• when the number of orders issued by the Customer exceeds the number of transactions performed;

• due to exceeding existing restrictions on the volume of the total customer position and/or the total number of placed orders for this type of account;

• if the Company failed to hedge a transaction with the help of the Liquidity Provider;

• under abnormal market conditions; or

• in any other case, at the sole discretion of the Company.

2.9. Determining the level of current market prices is the sole competence of the Company.

2.10. The opening of a trade operation to buy occurs at the price of ASK. Closing a trading operation for a purchase (i.e., sale) occurs at a BID price.

2.11. Opening a trade operation for sale (sell) occurs at the price of BID. Closing a trading operation for sale (i.e., purchase) occurs at the price of ASK.

2.12. The transfer of open positions onto the next day starts at 23:59:45 server time and is mandatory for all positions that remain open from 23:59:45 to 23:59:59 server time. Positions are transferred to the next day by charging the trading account or crediting to the Client’s trading account the amount calculated in accordance with the information on the website of the Company.

2.13. The spread is not fixed and varies depending on market conditions, as well as on streaming prices / liquidity received by the Company from liquidity providers.

2.14. In case of an unplanned interruption in the flow of quotes, the Company reserves the right to synchronize the quotation base on the server with other sources. In the event of a dispute caused by an interruption in the flow of quotes, all decisions are made in accordance with the synchronized quotation base.

2.15. The company has the right to transfer inactive trading accounts to the archive. The Client’s inactive trading account is transferred from the base of the trading terminal to the archive database, as a result of which the Client is blocked from access and cannot conduct any operations on the account, while the entire history and balance of the account are saved.

2.16. The client can restore the trading account transferred to the archive by submitting a corresponding request. The restoration of the trading account is carried out by the Company within 3 (three) business days from the date of receiving the application for the restoration of the trading account from the archive. After the restoration of the trading account, the Company shall notify the Client in writing about this.

2.17. A dividend adjustment may be applied to open CFDs on shares. It applies if such positions remained open on the Client’s account at the end of the trading session on the business day preceding the dividend payment day.

2.18. A company may recognize a quotation as non-market in the following cases:

• there is a significant price gap in the quote stream;

• after the price gap appears, the price returns to its original level in a short period of time;

• there is no sharp price movement before and after the occurrence of non-market quotes.

MARGIN REQUIREMENTS

3.1. The Company has the right to change the leverage of the Trading Account with the immediate entry into force of these changes and without prior notice. Leverage can be changed:

• in abnormal market conditions;

• in the event of an emergency;

• in case of force majeure or other force majeure circumstances.

3.2. The company has the right to apply new margin requirements in accordance with the previous paragraph both in relation to already open positions and in relation to newly opened positions.

3.3. The company has the right to change the leverage of individual customers at any time and at its own discretion with prior notification of the client by mail.

3.4. The Client undertakes to deposit and maintain the initial margin and (or) hedged margin in the amount established by the Company and indicated on the website of the Company.

3.5. Margin not nominated in the account currency will be converted into account currency at the current market price.

3.6. The company has the right to change the size of the margin:

• for all Clients with prior written notice;

• individually to any Client with prior written notice;

• individually to the Client in case of emergency without prior notice;

• to all Clients in the event of Force Majeure circumstances without prior notice.

3.7. The company has the right to apply the provisions of the previous paragraph both in relation to already opened positions and in relation to newly opened positions.

3.8. The client is obliged to independently monitor the level of margin on his trading account.

4. OPENING ORDERS

4.1. When opening an order, it is necessary for the Client to indicate the name of the trading instrument and the volume of the order.

4.2. To open a position, the Client in the client terminal must click the "Buy" button or the "Sell" button at the moment when the Company prices suit him.

4.3. Upon receipt of the Client’s order to open a position on the server, the Trading Account is checked for free margin.

4.4. If the trading account does not have enough funds to open an order, the Client’s order is rejected with the message “Not enough money”.

4.5. All actions of the Client to open positions are stored in the log file of the Company's trading server.

5. CLOSING POSITION

5.1. When closing an order, it is necessary for the Client to indicate the name of the trading instrument and the volume of the order.

5.2. To open a position, the Client in the client terminal must click the Close button at the moment when the Company prices suit him.

5.3. If during the processing of the Client’s order by the Company the quotation for the instrument has changed, the Company has the right to offer a new price (requote). If the Client agrees to close the order at the new proposed price, then he must press the “Ok” button in the client terminal within 3 seconds while the quote remains relevant. If during this time the Client does not accept the new price (does not click “Ok”), this means refusal to close the order.

5.4. All actions of the Client to close positions are stored in the log file of the Company's trading server.

6. PENDED ORDERS

6.1. Types of pending orders:

• Buy Limit. A purchase order at a price lower than the current one;

• Sell Limit. A sell order at a price higher than the current one;

• Buy Stop. Purchase order at a price higher than the current one;

• Sell Stop. A sell order at a price lower than the current one;

• Buy Stop Limit. Placement of a Buy Limit order when the ASK price reaches the level specified in the order;

• Sell Stop Limit. Placement of a Sell Limit order when the price reaches the BID level specified in the order;

• Stop Loss. Designed to limit losses. An order is closed at a price less favorable to the Client relative to the current market price.

• Take Profit. Designed for profit taking. Closing takes place at a price that is more favorable for the Client relative to the current market price.

6.2. The client may place, modify or delete orders only during the trading hours of the relevant instrument. The trading schedule for each instrument is indicated on the website of the Company, as well as in the client terminal.

6.3. When placing a pending order, the Client must specify the required parameters: name of the trading instrument, type of pending order, volume and order execution price. The client also has the right to specify additional parameters: Stop Loss and Take Profit levels and the date and time of expiration of the pending order.

6.4. An order to place a pending order will be rejected by the Company if either of the required parameters is not specified, or if any of the parameters is incorrect. At the same time, the Client will see a “Invalid S/L or T/P” error message in the terminal.

6.5. An order to place a pending order will be rejected by the Company if the order is received from the Client before the market opens.

6.6. When submitting an order, the difference between the level of the pending order and the current market price must be greater than or equal to the minimum value in points (Limit & Stop Level). Limit & Stop Level values ​​are indicated on the Company website. A company may increase its Limit & Stop Level during news releases that significantly affect market volatility, or in other conditions of an abnormal market.

6.7. If the Client submits an order to modify a pending order, he needs to indicate the ticket of the pending order, the level of the pending order, Stop Loss and Take Profit values.

6.8. An order to modify a pending order will be rejected if one of the above parameters is set incorrectly.

6.9. When a Client submits an Order to delete a pending order, the Client must indicate his ticket.

6.10. All actions of the Client to place pending orders are stored in the log file of the Company's trading server.

6.11. An order is queued for execution in the following cases:

• A Buy Limit order is placed in the queue for execution if the current Ask price reaches the level of the order;

• A Sell Limit order is placed in the execution queue if the current Bid price reaches the order level;

• A Buy Stop order is placed in the execution queue if the current Ask price reaches the order level;

• A Sell Stop order is placed in the execution queue if the current Bid price reaches the order level;

• A Take Profit order for an open Buy position is placed in the execution queue if the current Bid price reaches the order level;

• A Take Profit order for an open sell position (Sell) is placed in the execution queue if the current Ask price reaches the order level;

• A Stop Loss order for an open Buy position (Buy) is placed in the execution queue if the current Bid price reaches the order level;

• A Stop Loss order for an open Sell position (Sell) is placed in the execution queue if the current Ask price reaches the order level;

• In cases where both the level of a pending order and the level of the corresponding Stop Loss or Take Profit order fall into the price gap, the Company has the right to immediately open and close a position at the first available prices of the same quote.

6.12. All pending orders are queued for execution in the form of market orders and executed at an affordable market price.

6.13. Upon receipt of an order to execute a pending order on the server, the Trading Account is checked for free margin.

6.14. If the trading account does not contain enough funds to execute a pending order, the Company has the right not to open a position and delete the pending order with the entry “No money”.

6.15. If the level of a pending order or Stop Loss and Take Profit orders falls into the price gap, the orders are executed by the Company at the stated price or at the price available at the time of execution of the order. Execution price may differ from the order level.

6.16. An order to close a position will be rejected by the Company if it was received at the time when Stop Loss or Take Profit orders for this position were in the execution queue. In this case, the message “Off Quotes” appears in the client terminal.

7. FORCED CLOSURE OF POSITIONS

7.1. The Company has the right to forcibly close open positions of the Client without his consent and prior notice if the ratio of funds to margin on the Client’s trading account becomes equal to or falls below the Stop Out level.

7.2. Stop Out levels are listed on the Company's website.

7.3. Under abnormal market conditions, the Company does not guarantee the closure of open orders at the levels indicated on the Company's website.

7.4. In the event that the Client has several open positions on the trading account, the position with the largest floating loss is placed first in the line for forced closure.

7.5. In the event that the forced closure of orders led to the formation of a negative balance in the Client’s trading account, he is fully responsible for this loss. The Company is entitled to compensate for this loss at the expense of funds held in other accounts of the Client.

7.6. The company has the right every Friday one hour before the close of the trading session or at any other time, at its sole discretion, to make changes to the Stop Out levels and Margin requirements. The Company has the right to extend the validity of the above changes by providing the Client with a corresponding preliminary written notice.

7.7. If the Company changes the list of trading instruments, it has the right to forcefully close positions and delete pending orders for instruments that the Company ceases to provide. A position is closed at the last available price.

7.8. The Company has the right to close any open positions of the Client without prior notice, if necessary to resolve disputes.

8. INFORMATION EXCHANGE

8.1. For communication with the Client, the Company has the right to use the phone, e-mail, internal mail of the trading terminal, the website of the Company.

8.2 For communication with the Client, the Company will use the contact details provided by the Client when registering a personal account. Customer agrees to receive messages from the Company at any time.

8.3. Any information (news, announcements, documents, notifications, confirmations, reports, etc.) is considered received by the Client:

• immediately after the completion of the telephone conversation;

• immediately after sending by internal mail to the trading terminal;

• one hour after sending to his email address (e-mail);

• one hour after the announcement on the website of the Company.

8.4. The Client is obliged to promptly and as soon as possible notify the Company of any changes to his contact information.

9. TRADING OBLIGATIONS

9.1 When using term "trading circumstances" the company refers to any trading actions on the trading account that irrevocably affect the margin level, balance status, unreasonable trading operations that are placed contrary to the agreements that were concluded between the representatives of the company and / or its counter-parties and the client , in any form: electronic correspondence, verbal agreement, messages via e-mail or other means of communication.

9.1 The trading obligations undertaken by the client (entry time of the positions, exit time of the positions, volume of the positions, asset and other possible conditions) must be fully fulfilled.

9.2 When confirming the intention to participate in the collective trading pool of the company, the client is obliged to fully act in accordance with the terms and conditions, which are provided by the company.

9.3 In case of a unilateral refusal to fulfill the obligations previously taken by the client, the company reserves the right to freeze the trading account until the final settlement of the dispute.

9.4 If the actions of the client caused direct or indirect financial, reputational or any other type of damage done to the company or the company's counter-parties, the company reserves the right to recover the expenses caused by the client’s actions, from the client's trading account without prior notice of this action.

9.5 In case the client refuses to fulfill trading obligations, the company has the right, unilaterally, to refuse to provide service to the client, as well as to close the trading account / accounts of the client. The notification fo the client from the company in this case will be done via email.

9.6 A trading account or accounts of the client that has not fulfilled trading obligations on their part, may be blocked for trading, as well as for making deposits and withdrawals until the end of the internal audit and analysis of the client's actions by the relevant departments of DotBig.

9.7 The client has the right to receive full information regarding all the questions at the time of getting familiar with the trading conditions or any other conditions or documents present on the website, before the start of any financial or trading operations on their trading account.

AML/KYC Policy

1. INTRODUCTION

The Anti-Money Laundering and Know Your Customer Policy (the “AML/KYC Policy”) of DotBig Limited, company number 26350 BC 2021, registered at Suite 305, Griffinth Corporate Center, Kingstown, St. Vincent and Grenadines (“we”, “our”, “us” or “Company”) is established to prevent and mitigate possible risks of Company being involved in illegal or illicit activities and to enable Company to meet its legal and regulatory obligations in this area (if any, where applicable). This AML/KYC Policy is subject to changes and updates by the Company from time to time to ensure compliance with any applicable legislation and global AML/KYC practices.

2. SUBJECT MATTER

The Company AML & KYC Policy covers the following areas:

• KYC/AML identification procedures

• Ongoing monitoring of Users

• Sanctioned and Prohibited Jurisdictions

• Record-keeping

• Money Laundering Reporting Officer

• Training

3. KYC/AML IDENTIFICATION PROCEDURES

Prior to enabling or entering into a transaction with or for or on behalf of a User or providing any Service to a User, Company will:

• identify the User and verify the User’s identity on the basis of documents, data or other information based on a reliable and independent source;

• if there is a Beneficial Owner in relation to the User, identify the beneficial owner and take reasonable measures to verify the beneficial owner’s identity;

• To identify a User who is an individual, the Company will collect information from the User, including but not limited to, his full name, date of birth, citizenship, place of residence, email address, and the identity document type. Company will verify the identity of the User with documents such as his national ID, passport and/or driver’s license and utility bill.

4. ONGOING MONITORING OF USERS

Company reserves the right to continuously monitor, on a risk sensitive basis, the business relationship with a User (as applicable) by:

• reviewing from time to time documents, data and information that have been obtained by Company to ensure that such documents, data and information are up to date;

• conducting appropriate scrutiny of Transactions and activities carried out by Users to ensure that they are consistent with Company’s knowledge of the User’s business and risk profile, and to ensure that such Transactions and activities are in line with Company’s knowledge of the User’s or User’s source of funds and source of wealth; and

• identifying transactions that are unusually large in amount or of an unusual pattern and have no apparent economic or lawful purpose.

For the avoidance of doubt, Company may undertake ongoing monitoring on Users in order to ensure that any Transactions equal to or in excess of € 10 000 (or its equivalent in any other currency) shall be subject to Enhanced Customer Due Diligence in relation to the source of funds and source of wealth of the User.

To continuously monitor the business relationship with a User (as applicable), Company may carry out a file review to ensure that information held about the User is up-to-date and that identification documents held are still valid. In addition, on a more frequent basis, Company may also monitor transactional activity to identify any red-flags or ‘out of the norm’ activity.

As part of the second line of defense, the MLRO will carry out checks to ensure that regular and effective on-going monitoring is being affected and ensure that irregular or suspicious activities are effectively escalated.

5. SANCTIONED AND PROHIBITED JURISDICTIONS

Company has integrated with a leading electronic data provider to fulfil the regulatory obligations in line with Saint Lucia’s financial sanctions regime. Company will (with assistance of advisors and service providers, when necessary) establish and maintain the following lists of jurisdictions (i) Sanctioned Jurisdictions (any country or territory to the extent that such country or territory is the subject of any sanction issued by the United Nations, United States and/or the European Union) (ii) Prohibited Jurisdictions. In determining the list of Sanctioned Jurisdictions, Prohibited Jurisdictions, Company shall take into account the lists issued by the Financial Action Task Force and by other organizations issuing guidelines and lists relating to the adequacy of legislative measures adopted by jurisdictions in relation to money laundering, funding of terrorism and transparency.

Users which are (i) resident or domiciled in, or (ii) have their source of wealth or source of funds linked to a Sanctioned Jurisdiction and/or a Prohibited Jurisdiction shall not be accepted as clients of the Company.

Company will (and will always reserve a right to) screen a User on an ongoing basis, to ensure that such User is not a Sanctioned Person, from a Sanctioned Jurisdiction and/or a person from a Prohibited Jurisdiction.

Users which are (i) resident or domiciled in, or (ii) have their source of wealth or source of funds linked to High Risk Jurisdictions shall be subject to additional checks and measures by the Company.

In carrying out this screening Company shall ensure to adopt software to enable comprehensive screening to be carried out and which captures all sanctions that Company is bound to follow.

In addition to the aforementioned measures, we are integrated with the largest database of Politically Exposed Persons (PEPs), as well as those of their family members. Whenever a client has been identified as a PEP, enhanced due diligence measures are applied, senior management approval is necessary for establishing or continuing a business relationship with such a customer.

6. RECORD-KEEPING

Company will keep (a) transaction records including but not limited to the nature of the transaction, the amount of the transaction and the currency thereof, the date on which the transaction was conducted, the parties to the transaction, for a period of five (5) years beginning on the date on which a transaction is completed, or for such other minimal period as may be required by applicable law; and (b) other information collected by Company for AML/KYC purposes, throughout the continuance of the business relationship with the User and for a period of ten (10) years beginning on the date on which the business relationship with the User ends, or for such other minimal period as may be required by applicable law.

The Company may be required to cooperate with the government authorities within the territory of Saint Lucia or from outside the said territory therefore the Company may be obliged to disclose any information about the User to the said authorities, in particular, to the FIA (Financial Intelligence Authority).

7. MONEY LAUNDERING REPORTING OFFICER

The Money Laundering Reporting Officer (“MLRO”) shall be the person duly authorized by the Company, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the Money Laundering Reporting Officer’s responsibility to supervise all aspects of the Company's anti-money laundering and counter-terrorist financing. Once such an officer is appointed, all our employees will report any suspicious behavior or activities to the MLRO.

MLRO shall have the following duties:

• Receiving reports of any suspicious behavior or activities from our employees;

• Submitting Suspicious Transaction Reports to the authorities;

• Improving, updating and maintaining AML policies and procedures, incorporating new or changed regulations in the different markets;

• Monitoring, identifying and investigating suspicious activities whilst promptly implementing the right processes to mitigate such incidences;

• Maintaining and improving tools that inspect, analyze and report suspicious AML and fraud activity;

• Acting as the main point of contact for the local regulator;

• Ensuring that the Company complies with all applicable requirements;

• Establishing and maintaining effective systems and controls for compliance with applicable requirements and standards under the regulatory system;

• Providing advice to management of the Company on all applicable laws, regulations, rules & standards;

8. TRAINING

The Company maintains an ongoing employee training program so that the staff is adequately trained in AML/KYC procedures. Staff compliance with this policy will be monitored on a regular basis to ensure that the Company remains compliant with Saint Lucia’s AML law and regulation.

Privacy Policy

1. GENERAL

DotBig Limited, company number 26350 BC 2021, registered at Suite 305, Griffinth Corporate Center, Kingstown, St. Vincent and Grenadines (“Company”; “we”; “us”; “our”), and its affiliates, respect your privacy and value its importance, and are wholly committed to keeping your information safe and secure.

This Privacy Policy, together with our Client Agreement, governs the Company’s collection, processing and use of your Personal Information and applies whenever You access or use our Website dotbig.com or any other online services we provide (“the Services”).

We process your data in an appropriate and lawful manner, in accordance with the St. Lucia data protection laws (the “Regulation” ) and with other subsequent laws (“Data Protection Laws”).

It is important that you read this Policy together with any other privacy notices we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your data.

The Policy covers following questions:

• The data we collect about you
• How is your data collected
• How we use your Personal Data
• Data retention
• Disclosure of your Personal Data
• International transfers
• Data security
• Rights of users
• Minors
• Changes to the Privacy Policy and your duty to inform us of changes
• Our Contacts

2. THE DATA WE COLLECT ABOUT YOU

We may collect, use, store, and transfer different kinds of Personal Data about you as follows:

Identity Data: first, middle and last name, date of birth, citizenship, Passport / ID / Driving license number, username or similar identifier, marital status, title, date of birth, gender.

Contact Data: address (country, state, city, street, building number, flat number), e-mail address, phone numbers.

Transaction Data: debit/credit cards details, crypto wallet details, your transactional history on the Company’s platform, the payments made to and from you.

AML and KYC Data: (i) copy of your national identity document, passport and/or driver's license, (ii) proof of residence (for example, a recently issued utility bill, Internet/Cable TV/House phone line bills, bank statement, tax returns, council tax bills, the Government issued Certifications of Residency ), (iii) a ‘selfie' with passport/ID/Driving license (for identity verification), (iv) KYC database checks, (v) fraud database checks and (vi) any documentation or information which we may be from time to time mandated to collect by any competent authority, including, as applicable, any other documentation or information which may be mandated on us from time to time:

• required to collect to ensure compliance with any applicable legislation (including applicable foreign laws) and global AML/KYC practices; and/or

• otherwise mandated to collect by the Financial Intelligence Authority (FCI) and/or any other competent authority, including, as applicable, any other documentation or information which may be mandated on us from time to time by applicable law and by any other competent authority or related legislation (including overseas authorities and applicable foreign laws).

Technical Data: internet protocol (IP) address, your credential data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices which you (whether a client or otherwise) use to access and browse the Website, logs (all the users' actions on the Website)

Marketing and Communications Data: includes your preferences in receiving marketing from us or our third parties and your communication preferences. This may include information whether you have subscribed or unsubscribed from any of our mailing lists, attended any of our events, or accepted any of our invitations.

We will also collect, use and process any other information that you voluntarily choose to provide or disclose to us.

If you fail to provide Personal Data we may not be able to perform or conclude the contract which we have or are otherwise trying to enter into with you (namely regarding your account opening and provision of the Company’s services).

In certain cases, particularly where it relates to KYC due diligence data, we may need to exercise our prerogative to terminate our contract with you or decline to enter into a customer relationship with you.

We will however notify you if this is the case at the time.

3. HOW IS YOUR DATA COLLECTED

We generally use different methods to collect data from and about you including through:

Direct interaction with you

You consent to giving us information about you by filling in forms on our Website, complete the required application steps, request and receive our Services.

Automated technologies or interactions

When you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this Personal Data by using cookies, server logs and other similar technologies.

Please see our Cookie Policy for further details.

Third parties or publicly available sources

We may receive Personal Data about you from various third parties (for ex. outsourced third- party KYC providers) and public sources.

4. HOW WE USE YOUR PERSONAL DATA

We are careful about how we use your information. We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

Where you wish and consent to enter into a customer relationship with us.

Where we need to perform the contract we have, or which are about to enter with you as a customer.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where we need to comply with a legal or regulatory obligation.

Note that we may process your Personal Data pursuant to more than one lawful ground or basis, depending on the specific purpose for which we are using your data.

We collect, use and exchange your information for the following purposes:

• To set up your account and to provide the Services;
• To identify and authenticate your access to certain features of the Services;
• To authenticate your identity for the purpose of compliance with regulatory Know Your Customer requirements;
• To communicate with you, to deliver Services and to keep you informed of our latest updates;
• To market our website and the Services;
• To perform research or to conduct analytics in order to improve and customize the Services to your needs and interests;
• To support and troubleshoot the Services and to respond to your queries;
• To investigate and resolve disputes in connection with your use of the Services;
• To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services; and
• To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.

We shall use the Personal Data in compliance with the confidentiality and only use such data as far and as long as this is necessary for the purposes of the Website utilization, rendering of Services and for keeping Website users informed of our Services.

5. DATA RETENTION

We will only retain your Personal Data for as long as necessary to fulfil the purposes for which we collected it and, thereafter:

• for the purpose of satisfying any legal, accounting, tax, anti-money laundering and regulatory obligations or reporting requirements to which we may be subject; and/or
• to the extent that we may also need to retain your Personal Data to be able to assert, exercise or defend possible future legal claims against you or that otherwise involve you.

In the event that you do not use the account for the period of 2 (two) years and its balance equals to zero then we will treat the account as expired and your Personal Data may be deleted.

The company can and will store your personal data for the period of (6) six years from the termination of your customer relationship with the Company (which would typically arise from the closure or termination of your customer account). This retention period enables us to make use of your Personal Data for any applicable AML retention and reporting obligations, and for the filing, exercise or defence of possible future legal claims. In certain cases, we may need to retain your Personal Data for a period of up to ten (10) years in order to comply with applicable accounting and tax laws (this will primarily consist of your Transaction Data). There may also be instances where the need to retain Personal Data for longer periods, as dictated by the nature of the products and services provided.

6. DISCLOSURE OF YOUR PERSONAL DATA

We may share Personal Information with the following recipients which may be in or outside your jurisdiction: (i) our subsidiaries; (ii) affiliated companies; (iii) subcontractors and other third-party service providers; (iv) auditors or advisers of our business processes; and (v) any potential purchasers or investors in the Company.

We may share your Personal Data with law enforcement agencies, public authorities and judicial bodies (local and overseas).

We require all affiliated entities and third-party service providers to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow them to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our documented instructions.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

We also limit access to your Personal Data to strictly those employees, agents, contractors and third parties that have a professional ‘need-to-know'. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. All our employees have received appropriate training on data protection.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. RIGHTS OF USERS

• You have certain rights with respect to your Personal Data according to Data Protection Laws as specified below:
• Request access to your Personal Data.
• Request Correction of your Personal Data.
• Object to processing of the Personal Data.
• Request restriction of processing your Personal Data.
• Request transfer of your Personal Data.
• Right to withdraw consent.
• If you wish to exercise any of the rights set out above, please contact us at [email protected]. No fee is usually charged. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
• You have the right to lodge a complaint at any time to a competent supervisory authority on data protection matters, such as (in particular) the supervisory authority in the place of your habitual residence or your place of work.
• We would, however, appreciate the opportunity to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance at [email protected].

9. MINORS

The Services are not designated to individuals under the age of 18. If you are under 18 years old, you should not use the Services or provide any Personal Information to us.

We reserve the right to access and verify any Personal Information collected from you. In the event that we become aware that an individual under the age of 18 has shared any of their information, we will discard such information. If you have any reason to believe that a minor has shared any information with us, please contact us at [email protected].

10. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US ON CHANGES

We may revise this Privacy Policy from time to time, at our sole discretion, and the most current version will always be posted on our website. In the event of a material change to the Privacy Policy, we may notify you through the Services or via email. We encourage you to review this Privacy Policy regularly for any changes.

It is imperative that the Personal Data we hold about you is accurate and current at all times. Otherwise, this will impair our ability to provide you with the Services that you may request from us.

Please keep us informed if any of your Personal Data changes during our relationship with you.

11. OUR CONTACT DETAILS

Full name of legal entity: DotBig Limited

Email address: [email protected]

Postal address: Suite 305, Griffith Corporate Center, Kingstown, VC0100, St. Vincent and Grenadines

Please use the words ‘Data Protection Matter' in the subject line.

Cookie Policy

This Cookie Policy explains how Dotbig Limited, company number 2020-00035, registered Rodney Bayside Building, Rodney Bay, Gros-Islet, St. Lucia (“NAME”; “we”; “us”; “our”), and its affiliates use cookies and similar technologies when you visit our website dotbig.com (the "Website or Site"). It explains what these technologies are and why we use them, as well as your rights to control our use of them.

If you have any questions about our use of cookies or other technologies, please email us at [email protected].

If you do not agree to the practices outlined in this Policy, you must exit the Site.

WHAT ARE 'COOKIES'

The Website uses cookies to distinguish you from other users. They allow us to analyze trends and administer the Website, to help us to provide you with a good experience when you browse the Website and to develop and improve the Website at the same time.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive. A cookie enables the website to remember users that have already visited. Without a cookie, every time you open a new web page, the server where that page is stored will treat you like a completely new visitor. Cookies allow us to remember your custom preferences such as your language preference and allow you to complete tasks without having to re-enter your information when browsing.

Cookies typically contain the name of the website that the cookie came from, the lifetime of the cookie as well as a randomly generated unique number. Websites typically use this number to ensure that you are recognized when you visit the website again, while you move from page to page within one website and that any information you have entered is remembered.

WHAT INFORMATION DO WE COLLECT FROM COOKIES

Each time you visit our Website, a cookie is issued to record your visit.

We primarily use the following cookies:

Strictly necessary cookies.
These are cookies that are required for the operation of the Website. By way of illustration, these include cookies that enable you to log into secure areas of the Site and make use of its various functions

Analytical or performance cookies.

They allow us to recognize and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way the Site works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies

These are used to recognize you when you return to the Website and attempt to log-in to your account. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting cookies

These cookies record your visit to the Website, the pages you have visited and the links you have followed. We will use this information to make the Website and the advertising displayed on it more relevant to your interests.

Sessions cookies

These enable us to record session information, including the data and duration of your visit to the Website, the web pages which you viewed during your visit, your IP Address, the type and browser which you used, and your computer's operating system.

We do not use cookies to collect or store any personal information.

The statistical analysis which we obtain from cookies allows us to improve the Website, to generally make your internet experience more enjoyable and to provide a value- added service.

Please note that third parties (including advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical and performance cookies or targeting cookies.

ACCEPTANCE AND BLOCKING OF COOKIES

You do not have to accept cookies to use our Website.

You can control the use of cookies at the individual browser level, and can even block or reject all or some cookies by activating the relevant setting on your browser. If you do block or reject cookies, you may still be able to access and use the Site, but your ability to use some of its features and areas, together with the services that you connect to through the Site, may be limited or may simply not function properly.

Many browsers also allow you to browse privately, whereby cookies are automatically erased after you visit a site. The following is a list of the most common browsers and the way in which you can activate private browsing when using them:

• INTERNET EXPLORER 8 AND LATER VERSIONS: IN PRIVATE
• SAFARI 2 AND LATER VERSIONS: PRIVATE NAVIGATION/BROWSING
• FIREFOX 3.5 AND LATER VERSIONS: PRIVATE NAVIGATION/BROWSING
• GOOGLE CHROME 10 AND LATER VERSIONS: INCOGNITO

Further information on cookies can be found on various sites such as www.allaboutcookies.com

In that regard, we also use ‘web beacons' or ‘action tags' in conjunction with cookies. Web beacons are typically a minute and transparent graphic image that is placed on a website or in an email. Web beacons allow the website to record the simple actions of the user opening the page that contains the web beacon.

Since web beacons are the same as any other content on a web page, you cannot opt out or refuse them, however, these can be rendered ineffective by changing your browser's cookie settings to refuse cookies.

SOCIAL MEDIA FEATURES AND WIDGETS

The Site includes social media features. These features may collect your IP address, which pages you are visiting on the Site, and may set a cookie to enable this feature to function properly.

Any personal information that you provide via such social media applications may be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.

OTHER INFORMATION STORED

For security and troubleshooting purposes our web server stores logs of activity on the website.
The information stored includes: date, time, IP, page visited, result, amount of data sent and browser used.

Refund policy

GENERAL TERMS 

1.1. The Refund Policy (hereafter – "the Refund Policy") is a constituent and integral part of the Terms and Conditions. 

1.2. The Refund Policy is developed in accordance with the international legislation concerning combating (prevention) of criminal activity, money laundering and terrorism financing. 

1.3. Main objectives of the Refund Policy are: 

providing quality services to the customers of DotBig Limited (hereafter - the Company); 
reduction of financial and legal risks of the Company; 
observance of the principles of Anti-Money Laundering and Counter-Terrorism Financing and the "Know Your Customer" Policies.

GENERAL PRINCIPLES OF REFUND POLICY

2.1. The Company has the right to unilaterally block access to the Trader’s Room/suspend trading activities on the accounts/cancel deposit/withdrawal requests or transfer the funds back to the transmitter in case if the source of funds or the customer’s activity contravene the AML/KYC Policy.

2.2. In case of the violation of any of the clauses of this agreement or its supplements as well as violation of any clauses of AML policy, the Company reserves the right to refund money deposited via any payment system including credit/debit cards. In such case, refund will be performed only to the same payment account which the Client used for making deposit/withdrawal. The refund requests are to be proceeded within 45 business days since the moment such request is created. The first created request would take precedence over the other requests in case multiple withdrawal requests are created.

2.3. If the employee classifies the customer’s activity (particularly, depositing/withdrawing of funds) as non-compliant/contrary to the conventional purpose use of the Company’s services, where direct or indirect, illegal or unfair contemplation takes place, the Company reserves the right to act within the terms of this document without preliminary notifying (of) the customer. All direct and indirect losses; the expenses relating to funds transfer shall be reimbursed to the Company account of the customer’s funds.

2.4. In case of funding a trading account/personal account of the customer using a bank card, the customer is obligated not to ask for refunding of already credited funds to a trading account/personal payment account directly to the bank or to the card issuer as well as during or after the termination of the Company’s services use (usage). Any kind of such effort may be regarded by the Company as a violation of the Terms and Conditions, which may form a ground for bringing the customer to administrative/criminal responsibility in accordance with the national legislation. In case the Customer asks for refund, the Company reserves the right to block access to the Trader’s Room/suspend trading activity on the customer’s accounts and transfer the funds back to the trading account/personal account of the customer after paying all services and commission fees.

2.5. In case of a wrong transfer, made by the Client when depositing funds into their trading account, money is refunded only via the payment methods available in the Personal Area. Additional fees and other costs of each transfer method are listed on the Company’s website and may be changed by the Company from time to time.

2.6. The Client agrees and fully understands that the Company does not provide the refunds of the losses due to any reasons.

Bonus Terms & Conditions

INTRODUCTION

1.1. This Agreement defines the procedure for providing customers with bonuses and the opportunity to participate in promotions held by the Company.

GENERAL PROVISIONS

2.1. The company has the right to offer customers bonuses and the opportunity to participate in various promotions.

2.2. The above bonuses and promotions are a privilege for the Client, and the Client may be refused be given the opportunity to receive bonuses at the sole discretion of the Company.

2.3. In some cases, the Company has the right to provide bonuses to the Client on conditions determined individually with the Client.

BONUS ENTRY

3.1. By agreement with the Client, the Company may credit bonus funds in the amount determined by the Company to the client’s account.

3.2. The bonus can be credited to the account both to maintain margin support for open positions, and as a privilege.

3.3. The amount of the bonus credited to the account is determined by the Company as a percentage of the amount of money deposited by the client, and in a completely individual manner.

BONUS PROCESSING

4.1. Withdrawal of funds from the account to which the bonus was credited is possible only after reaching the required volume of transactions. If funds are withdrawn before this condition is met, the entire bonus amount must be returned.

4.2. An internal transfer of funds from the trading account to which the bonus was credited is possible only after reaching the required volume of transactions. If funds are transferred before this condition is reached, the entire bonus amount must be returned.

4.3. The processing of each $1 of bonus funds is carried out:

• with a bonus amount of up to $ 20,000 - the trading volume must reach $ 10,000 for each $1 of bonus funds received;
• with a bonus amount of more than $ 20,000 - the trading volume must reach $ 20,000 for each $ 1 of bonus funds received.

4.4. When working out the bonus, the volume of transactions whose duration was less than 1 (one) minute will not be taken into account.

4.5. In the event that several bonuses were credited to the Client’s account, then their processing occurs in chronological order according to the date the bonus was credited.

4.6. If all the conditions for working out the bonus are fulfilled, bonus funds are transferred to the balance and can be withdrawn or transferred without restrictions.

CANCELLATION OF BONUS

5.1. If there is no activity on the trading account to which the bonus was credited, for more than two months (60 calendar days), the Company has the right to cancel bonus funds from the account.

5.2. In case of suspicion of fraud with the development or use of a bonus, the Company has the right to write off bonus funds and annul the profits made using the bonus.

5.3. The company has the right to write off bonus funds from the trading account and cancel the profit made using the bonus at its sole discretion.

Terms and Conditions

Risk Disclosure

GENERAL

DotBig Limited, company number 26350 BC 2021, registered at Suite 305, Griffinth Corporate Center, Kingstown, St. Vincent and Grenadines (“NAME”; “we”; “us”; “our”), warns you that trading in financial markets is an activity that has a high level of risk. This notice includes the widest - spread risks, although the list is not exhaustive.

CFD

CFD stands for “Contract For Difference”, meaning you are not buying the underlying asset, but rather purchasing a contract to settle the difference in the initial and ending price of the asset. When trading CFDs, you generally trade on margin, which means you only have to deposit a small percentage of the overall value of your position. This is known as “Leverage”, and even small market movements may have a great impact, negative or positive on your trading account.

If the market moves against you, you may sustain a total loss greater than the funds invested in a specific position. You are responsible for all losses on your account up to the equity in your account.

CFDs are not suited to the long term investor. If you hold a CFD open over a long period of time the associated costs such as overnight fees increase, and it may be more beneficial to buy the underlying asset instead.

MARGINAL TRADE RISK

When executing trading operations under margin trading conditions, even small market movements may have great impact on a Client’s trading account due to the effect of leverage. The Client must consider that if the trend on the market is against them, the Client may sustain a total loss of their initial margin and any additional funds deposited to maintain open positions. The Client shall hold full responsibility for all risks, financial resources used and the chosen trading strategy.

HIGHLY VOLATILE INSTRUMENTS

Some Financial Instruments trade within wide intraday ranges with volatile price movements. Therefore, the Client must carefully consider that there is a high risk of losses. The price of a Financial Instrument is derived from the price of the Underlying Asset in which the Financial Instruments refers to. Financial Instruments and related Underlying Markets can be highly volatile. The prices of Financial Instruments and the Underlying Asset may fluctuate rapidly and over wide ranges and may reflect unforeseeable events or changes in conditions, none of which can be controlled by the Client or the Company. Under certain market conditions it may be impossible for a Client Order to be executed at declared prices leading to losses. The prices of Financial Instruments and the Underlying Assets will be influenced by, amongst other things, changing supply and demand relationships, governmental, agricultural, commercial and trade programs and policies, national and international political and economic events and the prevailing psychological characteristics of the relevant market place.

TECHNICAL RISK

The Client accepts the risk caused by software or telecommunications facilities failures as well as by other technical problems.

The Company is not responsible for Client’s losses sustained due to nonobservance of instructions included in the platform client terminal user guide.

When executing trading operations through the client terminal, the Client shall assume the risk of financial loss, which can be caused by:

• the failure of Client hardware, software and internet connection;
• the improper operation of Client equipment;
• the wrong settings in the client terminal;
• delayed client terminal updates;

The Client acknowledges that at the moment of peak load there may be some difficulties in getting telephone communication with the duty operator, especially on the fast market (for example, when key economic indicators are released).

ABNORMAL MARKET CONDITIONS

The Client shall acknowledge that under abnormal market conditions, the execution time for Client instructions may increase.

COMMUNICATIONS

The Client shall assume the risk of any financial loss caused by the Client either not receiving a notification from the Company.

The Client shall acknowledge that unencrypted information transmitted by email is not protected from unauthorized access.

The Client shall agree that the Company has the right to delete messages sent to the Client through internal mail 3 (three) days after they have been sent, despite the fact that the Client may not have received them yet.

The Client shall hold full responsibility for the safekeeping of information received from the Company and assumes the risk of any financial loss caused by unauthorized access to the Client’s trading account by a third party.

FORCE MAJEURE

The Client shall assume all risks of financial loss caused by a force majeure.

STATUTORY PROHIBITIONS AND RESTRICTIONS

The Client shall assume all financial and other risks when completing operations (or actions connected with these operations) on financial markets that are statutorily prohibited or restricted by the legislation of the country in which the Client is resident.