Business Policy

Privacy Policy

        Bull Sphere, (the “Company”), is a company that adheres to ethical business operations, with the respect and compliance with applicable law and other policies. The Company is aware of the obligation to protect personal data and privacy of the Applicant, personnel and customers (“You”) as the key principle; therefore, this policy is made with the following details. 
        
        This policy has been made in order to inform you, as an Applicant, member of personnel and customer, of objectives and details concerning the collection, gathering, use and disclosure of personal data of yours, and for legal rights that are related to personal data. The Company has collected, used and disclosed  your personal data in order to achieve the objectives in accordance with the policies of the Company. Apart from the relationship in accordance with the business policy and agreement with the customer, the Company collects, uses and discloses your personal from your use of the products or services of the Company, which is still under the scope of this policy. 
        
        Concerning personal data that the Company collects, uses and disclosed:  
        
        “Personal Data” are data that can be used for directly and indirectly identifying You,   excluding the death, as follows: 
        
        Data Directly Provided by You from the collection of data from the Applicant, the interview and other means as defined by the Company and in other similar cases; and  
        
        Personal Data Retrieved or Accessed by the Company from Sources Other than You, or Indirectly Retrieved Data, such as  from governmental agencies, companies in financial business group, financial institutes, financial service providers, business allies, credit information companies and data service providers, which the Company can collect from other sources after attaining your consent, as prescribed by law, except a case where it is necessary for the Company as permitted by law or consented by you. 
        
        Your personal data that are collected, used and disclosed are personal data: name, surname, gender, age, date of birth, place of birth, marital status, marital status, nationality, national ID card, passport number, foreigner ID card, work histories, educational background, licenses and bank account number;// contact information such as address as in house registration, actual address for document delivery, your telephone number, e-mail, Line ID and social media data;// occupational data such as job position, rank in organization, agencies, salary, other remuneration and welfare, recorded work hours, job leaves, appointment, transfer, position change, probation evaluation, evaluation of work performance, skills and capabilities, personalities and behaviors; // data of instruments and tools such as IP address, MAC address, Cookie ID and IMEI;// third person data such as data of family members, contact data and data of person of reference;// other data such as the use of website, opinions, preferences, hobbies, results from writing examination and participation to different events or campaigns held by the Bank and other data that the law  prescribes as personal data.  
        
        Sensitive Personal Data are personal data in special type as prescribed by law such as nationality, religion, criminal record, health profile, incapability profile, biometric data or other data of the similar nature as prescribed by law. 
        
        In case of a minor, the submission of personal data for account activation, the documents to be downloaded and submitted are: Consent for Relationship Building through Account Activation,  together with Enclosures. 
            
        Unless especially indicates herein, your personal and sensitive personal data are collectively called, “Personal Data.”

        The personal data mean personal data of ordinary individual and juristic person that are necessary and are used for checking an individual’s identity and for providing services that suit you. Personal data are also used for processing each account’s request or participation in any other program of the Company and other necessary transactions. The treats to personal data are in accordance with policies that concur with laws, including anti-money laundering law, as well as business policy and agreement with customer that you have acknowledged at the completion of application. In addition, the Company can request for additional documents and data as deemed necessary and appropriate for checking your identity by dint of any other reason.  
        
        The Company will keep your personal data in accordance with technical and managerial measures for securing your Personal Data in the proper manner, with the compliance with policies, regulations and criteria for personal data protection and other regulations in accordance with information technology security standard. The Company may amend such policies, regulations and measures from time to time, as deemed necessary and appropriate.
        
        In addition, you can apply to exercise rights under policies and other regulations that are enforced or will be amended in the future, as well as criteria that the Company sets.
        
        Since the Company is running business in several countries, there might be necessity for the Company to send or transfer your personal data to other companies in the same group/business inside and outside the country. Some foreign countries may have superior or inferior personal data protection measures, including the measures of personal data retention. The Company may send data to other recipient, which is part of normal business operation of the Company. In case where the destination country has measure that does not meet standard, the Company will manage to ensure that the delivery or transfer of personal data is carried out in the way that meets acceptable standard or as protected by law, or as necessary and concurrent with the confidentiality measure as prescribed by law if that country. 
        
        Cookie is a small file or data set that is stored in web browser of the visitor of the website, which is partly helping the website memorize the visit of the website, which is used in the website or system in order to enhance the efficiency of the visit by the customer of the Company. Each customer can turn off the cookie while normally using the website.
        
        In case where there is the detection that you have provided your personal data to activate your account in a way different from the objectives or as concealed act, the Company can take legal action immediately.
        
        Even though you terminate or stop the relationship, which includes any legal transaction with the Company, the Company will keep your personal data for five more years. However, the Company May delete/destroy your personal data or make your personal data unidentifiable to you when such data are no longer necessary or at the end of the aforementioned period or in any other case without the need for giving to you any prior notification. 
        
        If you have any recommendation or would like to inquire for detailed information concerning the collection, use and disclosure of your personal data and to request to exercise your rights in accordance with this policy, please contact the Company through the following channels.
           

 

Business Policy

 

Business policies coincide with general business conditions, which consisted of two sections. It describes the process of non-trading activities on the Client's trading account including trading operations, conflict resolution procedures, and Client communication.

 

 

The two sections mentioned above are:

1. General requirements
   1. Bid terms

Bid terms are based on the account type used by the Client:

1. For Interbank account:

 

• The Company calculates prices on all traded instruments in real-time based on market conditions and current prices or liquidity provided by liquidity providers and will quote to the Clients occasionally in the form of a market overview.

 

• All bids received by the Client through the Client's platform are Indicative that show the best Bid Price and Ask Price in the market received from liquidity providers.

 

• The Client agrees to the following conditions.

 

• The Company has the right to reject a bid if the price has not changed from the previous overall market price.

 

• Within the Client's Platform, the Client may not receive all prices contained in the price stream in the interval between individual price list snapshots.

 

1. For Market maker accounts:

 

• Prices published on the Company's website are Indicative.

 

• The quoted price may differ from the price of the underlying asset if the underlying market is closed. The price quoted by the Company shall be the approximate price of the underlying asset.

 

• The Company determines the spread and/or commission on the trading of each financial instrument in the contract specifications. The spread displayed on the Company's website is the standard spread (average spread) 1, the standard spread size may increase or decrease depending on market volatility. The company has the right to modify the spread and/or 2 commissions on trades without prior written notice to the Client.

 

1. If the price stream from the server is disrupted or disrupted due to a device or software problem, the Company has the right to use prices from other sources based on the servers serving the Clients where the trades are executed.

 

1. Other price service sources include:

 

• Other trading server or demo account server.

 

• Other price providers.

 

1. If a conflict arises due to interruption or disruption of the price stream, all price determinations are made on bases derived from other price providers.

 

 

1. Modification

 

1. Decision on modification or resize value and/or transaction amount (and/or price level and order size) shall be at the sole discretion of the Company. The Company's judgment is final and binding on the Client.

 

1. Such information shall be posted on the Company's website and the Client's Platform. If the information on the Company's website does not correspond with the information on the Client's platform, such information will be based on the information on the Client's platform.

 

1. if applicable (for example, if the collateral is a share that the issuer pays as a dividend), the dividend balance is adjusted based on the open positions in collateral held at the date the right to receive the dividends belongs to the existing shareholders (Ex-Dividend Day). The dividend amount will be credited to the Client's trading account if the Client buys, i.e., open a buy position (Buy), and will be deducted from the Client's account if the Client sells or opens a sell position (Sell).

 

1. Identity Verification

 

1. Verification of the Client's identity is intended to prevent unauthorized access to the account.

 

1. During the registration of the trading account, the Client must provide the Company with accurate and true information to verify identity under the Articles of Association of the Company (hereinafter referred to as "identification information"). If the identity information is changed, the Client must notify the Company within a reasonable period.

 

1. Personal information to be verified includes Information according to ID card or passport, registered address, email address, and telephone number.

 

1. Personal details and address as stated in the passport will be confirmed against the documents submitted by the Client, the address verification part can be used to invoice utilities, telephone, or electricity bills and will be verified through an email address verification code. We will verify the phone number by sending the code via SMS or calls from the company’s employee.

 

1. List of non-trading activities the Client must verify their identity before making a transaction, including:

 

• Withdrawal command

 

• Modification of access information

 

1. Methods used to verify a client’s identity (security type) are:

 

• Email

 

• SMS

 

1. Email security types: the Company sends a verification code to the Client via the Clients email which was notified during registration. Such verification codes must be used on the Company's website for processing non-trading operations that require identity verification.

 

1. SMS security types: The company sends the verification code to the Client's phone which was notified during registration. Such verification codes must be used on the Company's website for processing non-trading operations that require identity verification.

 

1. Client can choose a security type while registering.

 

1. The Client may request to modify the security type if the information provided by the Client as requested by the Company corresponds to the information in the document the Client provided during registration. If the Client modifies the security type, the Client can request withdrawals 3 business days after such modification.

 

1. The company reserves the right to suspend non-trading activities, if the information the Client uses to verify identity is incorrect or the document cannot be used to verify the identity or if the Client does not submit the documents requested by the Company.

 

1. If the Client forgets the password and e-mail specified during registration, after a complete inspection, the Company will close the account and transfer funds back to the bank account used to deposit funds in proportion to the deposit.

 

1. To verify the identity of the Client, the Company has the right to request the following documents at any time after the registration of a trading account.

 

• For individual clients, i.e., identity verification documents.

 

• For corporate clients such as documents of incorporation and documents confirming the status of the Company.

 

 

 

1. Suspicious Action
   1. The Company monitors compliance with the General Business Conditions and is responsible for investigating any suspicious activity of the Client to stop such action within a reasonable period.

 

1. If an investigation into a suspicious activity of the Client, the Company is obliged to request from the Client the necessary documents for the investigation.

 

1. Behavior that represents suspicious action:

 

• Transfer large amounts of funds without any activity on the trading account.

 

• Conducting irrational economic behavior or other legally impacted purposes.

 

• The Client refuses to submit documents presenting personal information to verify their identity or the Company is unable to verify the Client's identity.

 

• The Client attempts several non-trading transactions for the benefit of a third party.

 

• Documents submitted by the Client are forged, do not correspond, submit documents at different times, and impersonate documents.

 

1. Behavior considered suspicious is not limited to the activities mentioned above. Such a transaction could be considered a suspicious transaction if the Company's experts analyze it and deemed a suspicious act.

 

1. The company has the right to cancel any suspicious actions of the Client and/or charge client deposit or withdrawal fees and/or suspend all client trading accounts including the trading accounts of other clients in connection with these operations. In such case, the Client's funds will be withdrawn by a method convenient to the Company.

 

2. Transaction

 

1. General Terms

 

1. The Client Platform is a tool that allows the Client to access their Interbank account (i.e., ECN account) and open a Market Maker account.

 

1. The Buy order (Buy position) will be opened at the Ask price.

 

A Sell order (sell position) will be opened at the Bid price.

 

1. All open positions will be carried forward the next day from 9:59:00 to 22:00:00 server time.

 

1. The spread is not fixed; however, the market condition dictates the size of the spread. The average spread is shown in the contract specifications on the Company's website. Spread and/or the commission on the trading of financial instruments may vary between account types and the Client must ensure that the Client understands the relevant information as stated in the contract specifications on the Company's website.

 

1. The types of order execution are Instant Execution and Market Execution. The types of order execution used in each pair of financial instruments are shown in the contract specifications.

 

1. If necessary, the Company may modify the type of execution of the Financial Instruments order by notifying the Client 24 hours' notice in advance.

 

1. The Client's Platform will be the primary channel through which the Client can submit requests and orders. The Client will only be entitled to use the service to place orders by telephone through the operator if the Client's Platform is not available.

 

1. Client’s Request and Orders

 

1. The Company has the right to reject the Client's orders or orders in connection with the Market Maker Account in the following cases:

 

• The Client does not place an order while the price is in effect from the price received through the Client's platform or by telephone.

 

• The Company failed to receive the Client's order due to interruption or interruption of telephone communications or Internet signal caused by events beyond the Company's control.

 

• Price of the requested order shows apparent error.

 

• Price requested is not the market price.

 

• The number of lots is less than the minimum lots specified in the contract specifications.

 

• Force majeure events accorded in the Client Agreement.

 

• A position is opened with less free margin than the initial margin required for the position.

 

• Unable to confirm prices of the financial instrument, Clients will notify with an error stating "incorrect price" or "off quotes" etc.

 

• If there is maintenance on company equipment.

 

• The Client became insolvent.

 

• In relation to hedged positions, while requested to close Buy (Buy) and Sell (Sell) positions and free margin is less than the margin required to maintain open positions, to elaborate, Buy and Sell positions of a financial instrument are larger than those of the same financial instrument opened in opposite directions, this rule applies in respect of the transaction size that is considered a position as hedging.

 

1. The Company has the right to reject a client’s request or order in connection with an Interbank account in the cases specified in the terms 2.2.1 in this business policy or general business conditions, If the liquidity provider does not have sufficient liquidity to open a position or when the liquidity provider refuses to carry out such a transaction.

 

1. If a previously processed transaction is canceled or the liquidity provider modifies the price, such change will be reflected in the client's trading account.

 

1. Clients are considered insolvent in the following cases:

 

• The Client fails to perform the duties outlined in the Client Agreement and its annexes, and other relevant provisions specified.

 

• The Client fails to comply with the margin requirements and terms.

 

• The client was declared bankrupt by the court.

 

1. If the Client is insolvent, the Company can take the following action (without prior written notice).

 

• Close all positions or open positions at the current market price.

 

• Amortization of the balance in the trading account that the Client owes the Company.

 

• Close trading accounts possessed by the Client.

 

1. If a client’s request or order is rejected, such a message will be displayed on the Client’s platform.

 

1. The Company may decide to execute a client’s order on a special case even in the circumstances specified in Clause 2.2.4 of this Business Policy or these General Business Conditions.

 

1. If the automated trading systems (EA) send bulk orders that do not comply with economic sense (this includes attempting to open multiple orders with insufficient free margin and opening positions exceeding the maximum lot limit). The Company has the right to disable the automatic trading system until the error of the software is corrected.

 

1. Opening Status

 

1. If the Client wishes to order an opening position, the Client must specify the financial instrument they wish to trade and the number of lots they wish to open.

 

1. The trading volume in opening a position is calculated using the following formula:

 

• In trading CFDs on a currency pair, the volume of trade in an opening = number of lot x contract size x margin currency converted according to the US dollar exchange rate.

 

• In trading futures CFDs, the volume of trade in an opening = number of lot x minimum margin x margin currency converted according to the US dollar exchange rate.

 

1. Margin Currency is:

 

• In trading forexes, refers to the first currency in the currency pair.

 

• In trading futures CFDs, refers to the currency of its trading asset.

 

1. Financial Instruments processed by Immediate Execution method:

 

• If the Client wishes to open a position through the Client's terminal, the Client must click the "Buy" or "Sell" button while the price stream displays at the price the Client is satisfied with.

 

• If the price of the financial instrument currently displayed changes while in a process of ordering in the Client’s Market Maker account. The Company will offer a new price or refuse to process the order. In such a case, requote window or error message "Incorrect price" will display. If the Client wishes to open an order from the quoted offer, the Client must click “Accept” within three second period. The system will send the commands to the server again to be processed and verified. If the Client does not accept the quoted offer within three second period, the system will reject such transaction.

 

1. Financial instruments method that utilized market price are:

 

• If the Client wishes to open a position through the Client’s terminal, the Client must click “Buy by Market” or “Sell by Market”, the Client's open position may be executed at a price that differs from the price received by the Client on the Client's platform during the last market snapshot in the following cases:

 

• If the current price changes from the latest market price overview.

 

• If the latest market price overview applies to a trading volume that is less than the Client's trading volume.

 

• If the liquidity provider has executed an order at such a price.

 

• In any case, the Client's order is executed at the best price the Company receives from the liquidity provider.

 

• When the server receives an order from the Client to open a position, the position is automatically established with sufficient free margin to open the position under the margin requirements in effect at the period the position is opened for that financial instrument.

 

• The new status will be added to the list of open positions.

 

• The new "margin" value of existing positions with new pending positions will be calculated based on the current market price at all floating profit/loss positions for open positions including confirmed new pending positions are calculated from the current market price.

 

• The new "Free Margin" is calculated from:

 

• If the “Free Margin” is greater or equal to zero and all Client’s status and pending status does not exceed the limit of its account type, its status will then be opened. The process after opening the position is to save relevant information to the server log file.

 

• If the “Free Margin” is less than zero, the Company has the right to decline such an order.

 

• If opening a new position with the current spread causes a Margin Call alert or causes the equity to become negative, such a position will not be opened.

 

• The Company has the right to prohibit opening new positions in certain financial instruments for an indefinite period and without prior notice to the Client.

 

• An open status command is deemed successful when such a status command is saved in the server log file.

 

1.  Closing position

 

1. If the Client wishes to close a position, the client must specify a ticker and the number of lots wishes close.

 

1. Financial Instruments processed by Immediate Execution Method:

 

• To close a position through the Client's terminal, the Client presses the "Close ..." button while the Client sees the satisfied price displayed in the price flow.

 

1. Financial instruments method that utilized market price.

 

• To close a position through the Client's platform, the Client must press the "Close..." button.

 

• The Client's close order may be executed at a price that differs from the price received by the Client in the Client's terminal during the last market snapshot in the following cases:

 

• If the current price changes from the latest market price overview.

 

 

• If the latest market price overview applies to a trading volume that is less than the Client's trading volume.

 

• If the liquidity provider has executed an order at such a price.

 

1. In any case, the Client's order is executed at the best price the Company receives from the liquidity provider.

 

1. An order is deemed to be closed once that order is closed in the server.

 

1. Closing orders automatically (Stop Out)

 

1. The Company has the right to enforce the closure of the Client's position if the margin decreases to or below the required closing level or when the equity is negative.

 

1. If the Client has multiple open positions that must be closed, prioritize the largest floating loss.

 

1. If the automatic closing of order causes the equity in the Client's trading account to be negative. Such negative value will be compensated to bring the equity back to $0.

 

1. Trading Order

 

1. The type of order in the trading platform to open a position can be executed through the following commands:

 

• "Buy Limit Order" - an order to open a buy position (Buy) at a price lower than the current price the moment the order was opened.

 

• "Buy Stop Order" - an order to open a buy position (Buy) at a price higher than the current price the moment of opening a sell order.

 

• “Buy Stop Limit” is an order in a combination of the first two types of orders, it is a Stop order to issue a "Buy Limit Order" as soon as the Ask Price reaches a pre-defined level. During the process of setting "Buy Limit Order", the order will be opened at such price level. In addition, the current price is lower than the price will set open a pending order.

 

• "Sell Limit Order" - an order to open a sell position at a price higher than the current price the moment the order was opened.

 

• “Sell Stop Order” - an order to open a sell position at a price higher than the current price the moment the order was opened.

 

• A "Sell Stop Limit" order is a Stop order to open a "Sell Limit Order" as soon as the future "Bid" price reaches a preset level. During the process of setting an order, a "Sell Limit order" will be opened at such a price level. In addition, if the current price is higher the price will be set to open a pending order. However, the following commands can be initiated if the price of the pending order will be higher than the trigger price to close the position.

 

• “Stop Loss” - an order to close a previously opened position at a price that is less profitable than the price when the order was opened. “Take Profit” - an order to close a previously opened position at a profitable price that is higher than the price when the Client opened in a position.

 

1. Opening an order and its duration

 

• The Client may open, modify or delete orders on one financial instrument only within trading hours. The trading hours for each financial instrument are specified in the contract specifications.

 

• Futures orders of financial instruments that are traded 24 hours a day will be obtained a "Good Till Cancelled (GTC)" status. This means the order remains in effect until cancellation, the Client can determine an expiration date and time in the "Expiry" field.

 

• Futures orders of financial instruments that are not traded 24 hours a day will be indicated by a "Day Order" status. This means The order is valid until the end of its business day before being cleared from the system.

 

• Stop Loss and Take Profit orders for all financial instruments to have the status of "GTC" or "Good Till Cancelled".

 

• To open a pending order, the Client must specify the following variables: financial instruments, the number of lots of the order type, and the price at which the order will be opened. In addition, the Client may or may not specify secondary variables: the "Stop Loss" level, "Take Profit" level, and the expiration date of the pending order.

 

• The system will reject any orders that fail to specified application variables or an invalid value of a mandatory/secondary variable.

 

• If the Clients wish to open a "Stop Loss" or "Take Profit" order, the Client is required to provide the following information: Ticker of open positions and levels "Stop Loss" and "Take Profit".

 

1. In process of determining the Stop Loss and/or Take Profit orders to an open position or pending orders. Pending order price level (the difference between the Stop Loss or Take Profit pips) and the current market price must not be lower than the Limit and Stop Level specified for each instrument in the Contract Specifications, and the following conditions must also comply.

 

• For Stop Loss Order of a Sell (Sell) position, If the current market price is the Ask price, the order must not be opened at a price lower than the Ask price plus the Limit & Stop Level for such financial instrument.

 

• For Take Profit Order of a Sell (Sell) Position, If the current market price is the Ask price, the order must not be opened at a price higher than the Ask price minus the Limit & Stop Level for such financial instrument.

 

• For Stop Loss Order of a Buy (Buy) position, If the current market price is the Bid price, the order must not be opened at a price higher than the Bid price minus the Limit & Stop Level for such financial instrument.

 

• For Take Profit Order of a Buy (Buy) position, If the current market price is the Bid price, the order must not be opened at a price lower than the Bid price plus the Limit & Stop Level for such financial instrument.

 

• For Buy Limit Order, If the current market price is the Ask price, the order must not be opened at a price higher than the Ask price minus the Limit & Stop Level for such financial instrument.

 

• For Buy Stop Order, If the current market price is the Ask price, the order must not be opened at a price lower than the Ask price plus the Limit &Stop Level for such financial instrument.

 

• For Sell Limit Order, If the current market price is the Bid price, the order must not be opened at a price lower than the Bid price plus the Limit & Stop Level for such financial instrument.

 

• For Sell Stop Order, If the current market price is the Bid price, the order must not be opened at a price higher than the Bid price minus the Limit & Stop Level for such financial instrument.

 

1. An order is deemed to have been opened upon recorded in the server.

 

1. The Company will reject an opening order if the order was submitted prior to the first price at the opening of the market.

 

1. If the Client wishes to modify the value of the pending order variable, the following information must be provided: a ticker price level of pending orders "Stop Loss" and "Take Profit" levels. If the information provided is incorrect and the order is opened/modified/deleted through the Client's platform without Advisor, the order will be rejected and the "Modify" button will be unavailable.

 

1. If the client wishes to modify the "Stop Loss" and "Take Profit" orders that are opened, the Client must specify the Ticker "Stop Loss" level and "Take Profit" level. If the information provided is incorrect and the order is opened/modified/deleted through the Client's platform without Advisor, the order will be rejected and the "Modify" button will be unavailable.

 

1.  If the Client wishes to delete a pending order, A ticker must also be specified to be deemed to have been executed to modify or delete an instruction and to be deemed to have been modified or deleted when such a record is established in the server.

 

1. The Company has the right to refuse to modify the trading order, If the price of "Stop Loss" or "Take Profit" is set to the current price automatically executed while in process of modification.

 

1. The Company also has the right to refuse to open or modify pending orders if the Stop Loss order is closer to the opening price than the average spread gap.

 

1. The Company has the right to use the market price when executing Take Profit, Stop Loss, Buy Limit, Sell Limit, Buy Stop and Sell Stop orders. If the Client places Take Profit, Buy Limit and Sell Limit orders with a price discrepancy, the Client will earn more profit. However, If the client places Stop Loss, Buy Stop, and Sell Stop orders and a price discrepancy occurs, the Client will result in a loss of profit.

 

1. Order Execution

 

1. Pending orders will be executed when the following conditions are met:

 

• "Take Profit" of a pending Buy position is executed when the Bid price is equal to or higher than the order price level.

 

• "Stop Loss" of a pending Buy position is executed when the Bid price is equal to or below the order price level.

 

• "Take Profit" of a pending sell (Sell) position is executed when the Ask price is equal to or lower than the order price level.

 

• "Stop Loss" of pending sell (Sell) position will be executed when the Ask price is equal to or higher than the order price level.

 

• "Buy Limit" of a pending order is executed when the Ask price is equal to or below the order price level.

 

• “Sell Limit” of a pending order is executed when the Bid price is equal to or higher than the order price level.

 

• “Buy Stop” of a pending order is executed when the Ask price is equal to or higher than the order price level.

 

• “Sell Stop” of a pending order is executed when the Bid price is equal to or below the order's price level. The Company will try its best to execute the Limit order as close as the price requested by the Client. However, the Company may not be able to execute Limit orders for various reasons including but not limited to the following reasons: (1) There is an insufficient volume of orders in the underlying market. (2) The trading order exceeds the level of risk accepted by the Company, which is the level specified by the Company and amended occasionally under market conditions and other relevant factors. (3) Bid price or Ask price (depending on the Client’s Limit order) does not reach a certain level, such as: in a Sell order, the Bid price must reach the specified price. In a Buy order, the Ask price must reach the specified price.

 

1. Opening order for a Market Maker account on the server takes 0.01-5 seconds.

 

• When the price of order experiences a price gap during a market hour or in an abnormal market condition, the order is executed on the first price available in the market.

 

• The following rules apply to orders on certain currency pairs when the price experience a price gap specified in the contract specifications on the Company's website.

 

• If the order is executed in a different or abnormal market condition (e.g., low liquidity), or

 

• If the price specified in the pending order falls into the price gap and pip difference (complete value) between the first price on the market (adjacent price gap) with the price of the order greater than or equal to the number (price gap level) of a financial instrument.

 

• The order as specified in clause 1) or 2) above will be executed at the first market price after the gap, in other cases, all orders executed prices will be based on the prices specified in the order.

 

• Buy Stop, Sell Stop, and Stop Loss orders may be executed at a price level worse than specified by the Client. Buy Limit, Sell Limit and Take Profit orders may be executed at a price level better than the Client specified.

 

1. The Company has not established a period for processing the Client’s requests and orders on Interbank accounts. The duration depends on the liquidity provider to which the Company sends the requests and orders to be processed.

 

• In case of insufficient liquidity or the liquidity provider refuses to execute orders at the specified volume with market execution which will result in partial orders being processed and opened. The position can be opened and shall not exceed the volume available in the market or the volume that the liquidity provider has, and the rest of the orders will be canceled.

 

• In the event of insufficient liquidity or the liquidity provider refuses to execute orders at the specified volume with market execution which will result in partial orders being processed and opened. The position can be closed and shall not exceed the volume available in the market or the volume the liquidity provider has, the remaining positions will remain in the system.

 

• In case of insufficient liquidity or the liquidity provider refuses to execute orders at the specified volume with market execution which will result in partial execution of Buy Stop, Buy Limit, Sell Stop and Sell Limit orders. In this case, a partial order will be executed by opening a position based on the liquidity provided, and the remaining orders will be created for futures orders of the same types.

 

• In the event of insufficient liquidity or the liquidity provider refuses to execute orders at the specified volume with market execution which will result in partial execution of Stop Loss and Take Profit orders. It executes partial orders by closing positions based on liquidity provided and the remaining of the command, a new position will be established.

 

1. Resolving Conflict Situations

 

1. The Client has the right to lodge a complaint in the event of a conflict of interest. Please revise Client Complaint Handling which can be found on the Company's website and is subject to changes occasionally.

 

1. Server Data, Databases, and Server Log-File data are used as the primary data sources. With the Client’s complaint, if the Server Data, Database, and Server Log File data do not contain the Client Mentioned Records, the Company may not consider the dispute raised by the Client.

 

1. The Company will not consider any referred price from other Company.

 

1. The Company does not accept the following complaints:

 

• Client requests not being processed due to server maintenance or improvements.

 

• Client’s transactions arising from the use of temporary excess free margin which was obtained from a profitable position in the trading account and after that status is canceled and considered void.

 

• If the CFDs price of that trading instrument on the platform differs from the price of the underlying asset of that trading instrument.

 

1. The Company resolves all disputes from its causes of the complaint including reopening a wrongly closed position.

 

1. The Company will not compensate the Client if the issue occurred prior to the occurrence of the conflict as stated in the complaint.

 

1. Conflict Resolution Process

 

1. Modification and establishment of pending orders.

 

• The following cases are considered incorrectly opening or modifying pending orders.

 

• Making transactions before the market opens.

 

• Incorrect price

 

• Trading Platform experience issues

 

• Any pending orders or positions established pending order execution will be deleted.

 

• The Company will not accept complaints from the Client that is unable to issue a pending order or amend the price level of the pending order or the Company fails to fulfill the Client's order to amend or open a Client's order due to the Client's Internet signal, or of the server technical issue and the Company does not accept complaints arising from the causes specified in the Client Agreement and the Business Policy under the term specified in Clause 2.9.1 and others.

 

• If the Company has not resolved the dispute, the Company has the right to execute the pending orders in the order in which the server receives its request.

 

• In the process of conflict resolution, the Company will deny the Client’s complaints on inability to complete the transaction.

 

• After successfully resolving the conflict, the company will notify the Client of its decision.

 

1. Opening and Closing of status

 

• If the Client is unable to open or close a position, or if the Company is unable to execute the Client's order, the Company will accept the Client's complaint in the following cases: the Client’s signal or the server's connection is poor.

 

• Price error

 

• Transaction during the closing hour

 

• Trading Platform or the server’s software experiencing issues

 

• If the Client's account has insufficient funds to complete the transaction or the Client perform excessive transaction than its account type (Opening orders), the Company will accept the Client’s complaints regarding the inability to open additional positions.

 

• The Company can delete a Client's position if an order has been opened before the market opens or the order has been executed with the previous day's price or with an incorrect price.

 

• If the status has been deleted mistakenly, the Company has the right to decide its resolution by reopening the position or paying compensation to the Client.

 

• During the process of conflict resolution, the Company will not accept Client complaints regarding availability on transaction completion.

 

1. The meaning of the terms used in the General Business Terms and Client Agreement are correspond. However, should the definition in the Client Agreement differ, the term shall contain the following meanings:

 

• : Completed transactions and withdrawals in the trading account

 

“Account Type”: Conditions of Account Types with a list of account types offered by the Company can be found on the Trading Conditions page on www.bullsphere.com/, the client can choose its type of trading account during the registration process and its type is unable to be modified once selected. Some account types are reserved for specific groups of Clients. "Agent link" refers to the URL link used for new client referrals. After successful registration, the registrant will be the client of the Company under the Agent and the Agent will begin to receive the commission according to the formula specified in the Partner Agreement.

 

“Ask Price”: The higher the price in the quote, the price at which the Client may open an order.

 

• Auto Referral Activity”: When an agent broker receives a commission for trading through a trading account regulated by that brokerage agent directly or indirectly.

 

“Candlestick Charts”: A graph displaying the opening and closing prices as well as the highest and lowest prices within a specified period (for example, one minute, five minutes, one day, one week).

 

“Fundamental Asset Market”: Market where underlying assets are traded for CFDs.

 

“Bid Price”: The lower price in the quote is the price at which the client may open a sell order.

 

“Buy Limit”: Contained the meanings stated in the “Order” section of this Policy or the General Business Conditions.

 

“Buy Stop”: Contained the meanings stated in the “Order” section of this Policy or the General Business Conditions.

 

• : Prices displayed in the form of price charts for the period in relation to the bar/candlestick chart:

 

• The highest point of the bar/candlestick chart is the highest Bid price.

 

• The lowest point of the bar/candlestick chart is the lowest Bid price.

 

• The closing point of the bar/candlestick chart is the last Bid price of its period.

 

• The opening point of the bar/candlestick chart is the first Bid price.

 

“Log File on the Client’s platform”: A file created by the Client’s platform to record all requests and orders to be sent to the merchant within a second-by-second time frame.

 

“Company’s Account”: Company bank account and/or digital account including the Company account in the processing center.

 

“Conflict Situation”: 1) a situation in which the Client believes the Company has violated one or more of the provisions outlined in the Client Agreement and the Appendix, due to the Company’s action or inaction. 2) the situation in which the Company deems the Client has violated one or more of the provisions outlined in the Client Agreement and the Appendix, due to the Client’s action or inaction. 3) a situation in which the Client has carried out trading activities without market price or before the first price of the market opening, or the price received by the Client from the Company while the trading platform software has an apparent error or problem.

 

“Day Order”: Futures orders that are automatically cleared from the system at the end of the trading period.

 

“Electronic Payment System”: The procedures or processes of computer networks and software used to conduct financial transactions and make payments between the two users of the system. Its system is made of electronic money bank cards (e-money) and cash.

 

“Fast Market condition”: a condition in which the market moves rapidly for a short period, this often creates a price gap. This condition typically occurs briefly before a major event or immediately after an important event, such as:

 

• The release of macroeconomic indicators related to the global economy that impact financial markets greatly.

 

• Central Bank Interest Decisions.

 

• Press Releases and Speeches of the President of the Central Bank, Head of state Minister of Finance, and other important announcements.

 

• Intervention

 

• Terrorism

 

• Disasters or natural phenomena that cause a state of emergency to be declared (or other restrictive measures) within the affected state or territory.

 

• War or military-related operation.

 

• Political force majeure, removal, or appointment (including election results) of government executives.

 

• Any other similar events affecting price movements, not limited to causes listed above.

 

“Flat Market”: Market conditions in which prices are received infrequently through the platform for a longer period than normal market conditions. In principle, such market conditions are apparent during Christmas and public holidays in the country G7 From 20:00 - 24:00 GMT +0, etc.

 

“Successful Transaction”: Opening and closing positions of the same size with a typical buy/sell sequence.

 

“Good Till Canceled”: Order that remains in effect indefinitely until cancellation.

 

“Hedge Position”: Buy and Sell positions of the same size in the same financial instrument opened on the same trading account.

 

“Instant Execution”: Requesting an immediate execution of the order the Client sees on the Company's real-time price which the Client satisfied.

 

“Transfer orders to another trading account”: issuing orders through the personal area on the Company's website to transfer funds from the Client's trading account to another trading account registered with the Company.

 

“Limit and Stop Level”: The minimum value in units from the open order level to the current price. (price level of the pending order).

 

“liquidity Provider”: A financial institution with sufficient funds and acts as a partner of its Clients in executing orders for financial instruments through electronic communication networks (ECNs).

 

“Abnormal Market Condition”: A market with low trade activity or a market with unusual fast movement.

 

“Price Action”: Execution of the Client's orders with no guarantee of its execution at the requested price.

 

“Market Opening”: Resume trading after the weekend public holidays or breaks between trading.

 

“Maximum Deviation”: The maximum difference in price (in units) at which an order will be executed against the Client's requested price, which is set by the Client on the Client's platform for the position to be opened or closed through its price differs from the Client's requested price.

 

“Amendment”: The client’s request to amend the price level of the order, only when the relevant message appears in the server database shall be deemed successful.

 

“Spike”: The price has the following characteristics:

 

• A very wide price gap.

 

• Within a short period, the price returned to its original level resulting in a price gap.

 

• There is no price volatility prior to the price gap occurrence.

 

• The price is different from the price of other major service providers in the market greater than 10 percent.

 

• The price that occurs during the hours that the underlying asset is not traded.

 

• While the price is displayed, there are no macroeconomic factors and/or business news that significantly affect the exchange rate of the financial instrument. The Company has the right to remove any prices that appear to be non-market prices from the server base price.

 

“Non-Trading Activities”: These include depositing/withdrawing funds from the Client's trading account, changing passwords, changing leverage, and filing complaints.

 

“Normal Market Condition”: Market with the following conditions:

 

• There is a constant entry of prices into the trading platform, and

 

• No rapid movement in prices, and

 

• No price gaps.

 

“Ticket of Order”: The order number assigned to each open position or delayed order.

 

“Pending Order”: The Client's order to open a position when the market price reaches a preset price level.

 

“Pips”: Price change up to or down which is equal to ten (10) points.

 

“Point”: less significant unit of rate /unit of the smallest change in foreign currency price increasing or decreasing.

 

“Price Gap”: A situation in which the market price differs from the previous price that is greater than the minimum amount.

 

“Quoted Price”: Information on the current price of one of the underlying assets in the form of Bid and Ask prices.

 

“Price Offer”: The process of bidding on the Client for a transaction.

 

“Price Database”: Price flow data stored on the server.

 

“Rate”: 1) For trading CFDs on currency pairs is the value of the base currency compared to the minor currency. 2) For trading futures CFDs, it is the value of one unit of the underlying asset in monetary terms.

 

“Sell Limit”: Its meaning is stated in the “Orders” section in General Business Conditions.

 

“Sell Stop”: Its meaning is stated in the “Orders” section in General Business Conditions.

 

“Server’s Log File”: A file containing activity data of the server including the Client’s requests and orders

 

“Spread”: Refers to the difference between the Ask price and the Bid price.

 

“Stop-Loss”: An order to close a position at a price that yields less than the price at which the Client opened that position.

 

“Stop Out”: An order from the server that forces the status to close (without the need to obtain the Client's consent or notify the Client in advance as there are insufficient funds to maintain the position).

 

“Take Profit”: It is an order to close a position at a price that yields a better return than the price at which the Client opened initially.

 

“Trading Commission”: Fees charged for providing services.

 

“Trading Activity”: These include buying or selling activities of financial instruments and opening, modifying, and deleting futures orders.

 

“Trading Platform’s Time Zone”: The time zone in which the server log file and logs events. The publishing this document, the trading platform uses the GMT +0 time zone.

 

“Trail Stop”: An order within the Client's terminal that allows changing the Stop Loss level of an open position by a certain value without the Client’s inconvenience.

 

“Trading Volume”: Multiply the number of lots by the contract size.

 

“Limit”: An order from a Client to buy or sell a financial asset when the market price reaches the price specified in the order. The Limit order is always set at a price better than the current one.

 

“Stop”: An order from a Client to buy or sell a financial asset when the market price reaches the price specified in the order, the stop order is always set at a price worse than the current price.

 

“Underlying Market”: Related markets where CFD underlying assets are traded.