TradeOracle.com FLOW Services - MiFID II Disclosures

Effective Date: 26 December 2025

TradeOracle.com FLOW™ Services - MiFID II Disclosures

**Effective Date:** 26 December 2025 **Data Controller:** Trade Oracle Group, 2489 W Main St. Littleton, CO 80120

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IMPORTANT INFORMATION FOR EU USERS

This document contains additional terms, disclosures, and risk warnings required for users accessing TradeOracle.com services from European Union member states. These terms supplement (and where inconsistent, supersede) the general disclaimer and terms of service.

1. REGULATORY FRAMEWORK

MiFID II Applicability

Trade Oracle Group is a U.S.-based company and is NOT authorized under the Markets in Financial Instruments Directive (MiFID II) or the Markets in Financial Instruments Regulation (MiFIR).

We do not hold a license from any EU member state financial regulator. Our services are available to EU users under:

●     Reverse solicitation provisions, OR

●     National exemptions for third-country firms, OR

●     General business-to-business provisions

**Important:** You are not entitled to the protections afforded to clients of MiFID II-authorized investment firms.

Services Classification

Under MiFID II terminology, our services would be classified as:

**What We Provide:**

●     Technical analysis software (ancillary service, if anything)

●     Educational resources (not regulated)

●     Market data analysis tools (not regulated investment services)

**What We Do NOT Provide:**

●     Investment advice (Article 4(1)(4) MiFID II)

●     Portfolio management (Article 4(1)(8) MiFID II)

●     Reception and transmission of orders (Article 4(1)(1) MiFID II)

●     Execution of orders (Article 4(1)(2) MiFID II)

●     Any other MiFID II investment service

2. NOT INVESTMENT ADVICE

Definition Under MiFID II

Investment advice means "the provision of personal recommendations to a client, either upon its request or at the initiative of the investment firm, in respect of one or more transactions relating to financial instruments."

Why Our Service Is NOT Investment Advice

**1. Not Personal Recommendations:**

●     FLOW™ signals are generated by algorithms

●     Not tailored to your individual circumstances

●     Not based on assessment of your financial situation

●     Not considering your investment objectives

●     Not evaluating your risk tolerance

**2. Not Presented As Suitable:**

●     We do not represent signals as suitable for you

●     We do not assess your ability to understand risks

●     We do not perform suitability assessments

●     We do not consider appropriateness for your knowledge level

**3. General Analysis Only:**

●     Signals are based purely on technical market patterns

●     No consideration of fundamental factors specific to you

●     No review of your portfolio or asset allocation

●     No personalization of any kind

ESMA Guidance Compliance

Per ESMA's supervisory briefing (ESMA35-43-3861), the five tests for investment advice are:

1. Is there a recommendation? | No - automated signals, not recommendations 

2. Is it personal? No - generic, not tailored to individual

3. Regarding financial instruments? Signals relate to instruments, but see above

4. Presented as suitable? No - explicitly disclaimed

5. Based on person's circumstances? No - purely technical analysis

**Conclusion:** Our service does not constitute investment advice under MiFID II.

3. SUITABILITY AND APPROPRIATENESS

No Suitability Assessment

We do NOT assess whether any particular investment, strategy, or signal is suitable for you.

MiFID II requires suitability assessments for:

●     Investment advice services

●     Portfolio management services

Since we provide neither, we conduct no suitability assessment. This means we do not:

●     Review your financial situation

●     Assess your investment objectives

●     Evaluate your risk tolerance

●     Consider your knowledge and experience

●     Provide personalized guidance

**Your Responsibility:** You must make your own determination of suitability.

No Appropriateness Assessment

We do NOT conduct appropriateness assessments.

MiFID II requires appropriateness assessments for certain non-advised services. Since our service is purely technical analysis tools (not investment services), we do not conduct these assessments.

**Warning:** If you do not understand:

●     How derivative markets work

●     The concept of leverage

●     The risks of margin trading

●     Technical analysis principles

●     Algorithmic trading concepts

**Then this service is likely NOT appropriate for you, and you should not use it.**

4. DISCLOSURE REQUIREMENTS UNDER MIFID II

Article 44: Fair, Clear, and Not Misleading

All information provided through our platform is designed to comply with Article 44 standards:

**Fair:**

●     Balanced presentation of features and risks

●     No undue emphasis on benefits over risks

●     Honest representation of capabilities and limitations

**Clear:**

●     Plain language accessible to target audience

●     Technical terms defined

●     Logical structure and organization

**Not Misleading:**

●     No guarantees of profitability

●     Accurate description of services

●     No omission of material information

●     Clear distinction between actual and hypothetical results

Article 47: Information About Services

**Nature and Risks of Financial Instruments:**

●     We provide tools for analyzing financial instruments

●     We do not execute trades or provide instruments themselves

●     Risks of derivative trading are extensively disclosed (see Section 5)

**Nature and Risks of Service:**

●     Algorithmic analysis based on historical patterns

●     No guarantee patterns will repeat

●     Technology and data risks

●     User maintains all trading decisions and risks

**Costs and Associated Charges:**

●     Subscription fees clearly disclosed

●     No hidden charges

●     No performance fees tied to trading results

●     No commissions from brokers

●     Cancellation and refund policy clearly stated

5. COMPREHENSIVE RISK WARNINGS

⚠️ GENERAL RISK WARNING ⚠️

**Trading leveraged derivatives is highly speculative and involves substantial risk of loss.**

You could lose substantially more than your initial investment. Leveraged products can result in losses that exceed your account balance. These products are complex and may not be suitable for all investors.

**You should not invest money that you cannot afford to lose.**

Specific Risks of Derivative Trading

**Market Risk:**

●     Prices can move rapidly and unpredictably

●     Volatility can increase suddenly

●     Liquidity can disappear in stressed markets

●     Gap risk (prices jumping over stop losses)

●     Correlation breakdowns during crises

**Leverage Risk:**

●     Small market movements cause proportionately larger account movements

●     Leverage magnifies both profits and losses

●     You can lose more than your initial margin

●     Margin calls can force liquidation at unfavorable prices

●     Interest/financing costs on leveraged positions

**Liquidity Risk:**

●     Cannot close positions when desired

●     Bid-ask spreads widen during volatility

●     Slippage on entry and exit

●     Market gaps can prevent stops from executing

**Counterparty Risk:**

●     Your broker could fail

●     Clearing house could fail

●     Regulatory changes affecting positions

●     Segregation of funds may not fully protect you

**Technology Risk:**

●     Platform failures preventing trading

●     Internet connectivity issues

●     Data errors producing incorrect signals

●     Cyber attacks and security breaches

●     Order entry errors

**Algorithmic/Model Risk:**

●     FLOW™ is based on historical patterns

●     Past patterns may not repeat

●     Algorithms can fail in new market conditions

●     Over-fitting to historical data

●     Black swan events not in training data

●     Model assumptions may be violated

**Operational Risk:**

●     Human error in trade execution

●     Misunderstanding of signals

●     Emotional decision making

●     Poor risk management implementation

●     Account administration errors

**Regulatory and Legal Risk:**

●     Changes in financial regulations

●     Changes in tax treatment

●     Legal restrictions on trading

●     Jurisdictional issues

●     Contract enforceability

**Currency Risk (for non-EUR instruments):**

●     Exchange rate fluctuations

●     Currency-hedged positions may not be perfect

●     Cross-currency margin requirements

6. TARGET MARKET DISCLOSURE

Intended Target Market

This service is designed for clients with the following characteristics:

**Knowledge and Experience:**

●     ✓ Understanding of derivative markets

●     ✓ Experience trading futures, options, or CFDs

●     ✓ Familiarity with technical analysis

●     ✓ Understanding of leverage and margin

●     ✓ Ability to interpret algorithmic signals

**Financial Situation:**

●     ✓ Can afford to lose entire investment

●     ✓ Has separate emergency funds

●     ✓ Not using borrowed money

●     ✓ Not using funds needed for living expenses

●     ✓ Can withstand significant volatility

**Risk Tolerance:**

●     ✓ High risk tolerance

●     ✓ Seeks potentially high returns

●     ✓ Understands possibility of total loss

●     ✓ Will not be materially harmed by losses

●     ✓ Has diversified investment portfolio

**Investment Objectives:**

●     ✓ Seeking trading tools, not investment management

●     ✓ Active trading orientation

●     ✓ Short to medium-term time horizon

●     ✓ Speculative objectives acceptable

●     ✓ Seeking technical analysis assistance

Negative Target Market

This service is NOT designed for:

●     ✗ Individuals seeking guaranteed returns

●     ✗ Individuals who cannot afford losses

●     ✗ Individuals without derivative trading knowledge

●     ✗ Individuals seeking capital preservation

●     ✗ Individuals seeking passive investment solutions

●     ✗ Individuals requiring suitability assessments

●     ✗ Retail clients seeking MiFID II protections

●     ✗ Vulnerable customers (see Section 15)

Distribution Strategy

We distribute this product through:

●     Direct online subscription

●     Marketing to experienced traders

●     Educational content emphasizing risk

●     No active solicitation of unsuitable clients

We employ measures to ensure appropriate distribution:

●     Extensive risk warnings at sign-up

●     Requirement to acknowledge disclaimers

●     Educational materials available

●     Clear description of service limitations

7. BEST EXECUTION

Not Applicable

Article 27 of MiFID II requires best execution when executing orders on behalf of clients.

**We do not execute orders.** Therefore, we have no best execution obligations.

**Your Responsibility:**

●     Selecting your own broker

●     Ensuring your broker provides best execution

●     Understanding your broker's execution policy

●     Monitoring execution quality

8. CONFLICTS OF INTEREST POLICY

Article 23 Compliance

We maintain a conflicts of interest policy in accordance with MiFID II principles:

**Identified Conflicts:**

1. Subscription Revenue vs. User Success:

●     Potential conflict: Revenue whether users profit or not

●     Mitigation: No performance fees; fixed subscription model

2. Data Provider Relationships:

●     Conflict: Financial relationships with data vendors

●     Mitigation: Use multiple independent data sources; no exclusive arrangements affecting objectivity

3. Marketing vs. Suitability:

●     Conflict: Desire to grow user base vs. ensuring appropriate users

●     Mitigation: Extensive risk warnings; clear target market; discouraging unsuitable users

**No Material Conflicts:**

●     ✓ No broker relationships or commission sharing

●     ✓ No proprietary trading activities

●     ✓ No payment for order flow

●     ✓ No stake in user trading outcomes

●     ✓ No investment in competing services

**Management Procedures:**

●     Organizational separation of functions

●     Prohibition on conflicts affecting service delivery

●     Regular review of potential conflicts

●     Disclosure of all material conflicts

●     Prioritization of user interests where conflicts arise

9. INDUCEMENTS AND REMUNERATION

Article 24(9) - Prohibition on Inducements

For investment advice and portfolio management services, MiFID II prohibits certain inducements.

**Not Applicable to Our Service:** We provide neither investment advice nor portfolio management, so Article 24(9) restrictions do not apply.

**However, We Voluntarily:**

●     Accept no payments from brokers

●     Receive no commissions on trades

●     Have no revenue sharing with brokers

●     Are paid purely by subscription fees from users

Staff Remuneration

●     Staff compensation is not tied to:

●     User trading volume

●     User profitability or losses

●     Specific product recommendations

●     Encouraging unsuitable trading

●     Staff incentives based on:

●     Customer satisfaction

●     Service quality

●     Educational value

●     Platform reliability

10. PRODUCT GOVERNANCE

Manufacturer vs. Distributor

Under MiFID II product governance rules:

●     **Manufacturers** create financial products

●     **Distributors** offer products to clients

**We are neither a manufacturer nor distributor of financial instruments.**

We manufacture software tools for analysis. Financial instruments are:

●     Manufactured by exchanges, issuers, or product sponsors

●     Distributed by brokers

●     Neither manufactured nor distributed by us

**However, for our software service:**

**Design Process:**

●     Designed for experienced trader target market

●     Risk-aware orientation throughout design

●     Educational features to support informed use

●     Regular updates based on user feedback and market conditions

**Distribution Strategy:**

●     Marketing to appropriate target market

●     Extensive risk warnings in materials

●     Educational content screening for sophistication

●     No aggressive sales tactics

**Ongoing Monitoring:**

●     Review user complaints and feedback

●     Monitor service performance and reliability

●     Update risk warnings as needed

●     Enhance educational materials

●     Adapt to regulatory changes

11. COSTS AND CHARGES DISCLOSURE

Article 50 - Information on Costs and Charges

**Subscription Costs:** | Service | Cost | Billing Frequency | |---------|------|-------------------| | FLOW™ Basic | $[AMOUNT] | Monthly/Annual | | FLOW™ Plus | $[AMOUNT] | Monthly/Annual | | FLOW™ Signals | $[AMOUNT] | Monthly/Annual |

**No Additional Charges:**

●     ✓ No performance fees

●     ✓ No commissions

●     ✓ No success fees

●     ✓ No transaction charges

●     ✓ No withdrawal fees

●     ✓ No account maintenance fees

**Third-Party Costs:** Users are responsible for:

●     Broker commissions (set by your broker)

●     Exchange fees (if applicable)

●     Market data fees (your broker may charge)

●     Currency conversion fees (if applicable)

●     Financing costs on leveraged positions (margin interest)

**Refund Policy:** [Insert refund policy from main agreement, including any processing fees]

Ex-Ante vs. Ex-Post Disclosure

**Ex-Ante (Before Service):**

●     All costs disclosed before subscription

●     No hidden charges

●     Clear billing schedule

**Ex-Post (Annual Statement):**

●     Annual statement of fees paid available on request

●     Breakdown of subscription payments

●     No trading costs to report (we don't execute)

12. GDPR AND DATA PROTECTION

Legal Framework

We process personal data in accordance with:

●     EU General Data Protection Regulation (GDPR) - Regulation (EU) 2016/679

●     National implementations in EU member states

●     Other applicable data protection laws

Data Controller

**Name:** Trade Oracle Group **Address:** 2489 W Main St. Littleton, CO 80120 **Contact:** tradeoracle@proton.me

Data Protection Officer

Eric David

Lawful Basis for Processing

| Processing Activity | Legal Basis | Purpose | | Account creation & management | Contract (Article 6(1)(b)) | Provide subscribed services | | Payment processing | Contract (Article 6(1)(b)) | Billing and payment | | Service improvement | Legitimate Interest (Article 6(1)(f)) | Enhance platform functionality | | Fraud prevention | Legitimate Interest (Article 6(1)(f)) | Security and fraud detection | | Marketing (if consented) | Consent (Article 6(1)(a)) | Send promotional materials | | Legal compliance | Legal Obligation (Article 6(1)(c)) | Comply with applicable laws |

Data We Collect

**Account Information:**

●     Name, email address, phone number

●     Billing address

●     Payment method information (processed by third-party processor)

**Usage Data:**

●     Login times and frequency

●     Features accessed

●     Settings and preferences

●     Technical data (IP address, browser type, device information)

**Communication Data:**

●     Support inquiries and our responses

●     Survey responses

●     Feedback provided

**We Do NOT Collect:**

●     Your trading positions or account balances

●     Your broker information

●     Your actual trading decisions

●     Social Security numbers or national ID numbers (except as legally required)

Your Data Protection Rights

**Right of Access (Article 15):** Request copy of your personal data.

**Right to Rectification (Article 16):** Correct inaccurate data.

**Right to Erasure (Article 17):** Request deletion (subject to legal retention requirements).

**Right to Restrict Processing (Article 18):** Limit how we use your data.

**Right to Data Portability (Article 20):** Receive your data in structured, machine-readable format.

**Right to Object (Article 21):** Object to processing based on legitimate interests.

**Right to Withdraw Consent (Article 7(3)):** Withdraw marketing consent at any time.

**Right to Lodge Complaint:** Complain to your national supervisory authority.

**To exercise rights:** Email tradeoracle@proton.me with your request.

Data Retention

| Data Type | Retention Period | Billing Information: 12 months | Active account data | Duration of subscription | | Closed account data | 7 years (legal/tax requirements) | | Marketing data (if consented) | Until consent withdrawn | | Support communications | 3 years | | Financial records | 7 years (legal requirements) |

After retention periods, data is securely deleted or anonymized.

International Data Transfers

**Transfer to United States:** Your data is transferred to and processed in the United States. We implement appropriate safeguards:

**Standard Contractual Clauses (SCCs):**

●     We use EU Commission-approved SCCs for transfers

●     Contractual commitments with data processors

●     Regular review of adequacy

**Security Measures:**

●     Encryption in transit and at rest

●     Access controls and authentication

●     Regular security audits

●     Incident response procedures

●     Staff training on data protection

**Your Rights Regarding Transfers:** You may request information about:

●     Countries to which data is transferred

●     Safeguards in place

●     Copy of SCCs (where applicable)

Data Breaches

**Article 33/34 Compliance:**

●     We will notify the relevant supervisory authority within 72 hours of becoming aware of a breach (if required)

●     We will notify you directly if the breach is likely to result in high risk to your rights and freedoms

●     Notification will describe nature of breach, likely consequences, and measures taken

Third-Party Processors

We engage the following categories of processors:

●     Payment processors (for billing)

●     Cloud hosting services (for platform infrastructure)

●     Email service providers (for communications)

●     Analytics services (for service improvement)

All processors are contractually bound by:

●     GDPR Article 28 requirements

●     Confidentiality obligations

●     Security requirements

●     Sub-processor restrictions

Supervisory Authorities

You may lodge complaints with:

●     Your national data protection authority, OR

●     The Irish Data Protection Commission (if we have EU establishment)

**Find your authority:** https://edpb.europa.eu/about-edpb/board/members_en

13. PROFESSIONAL SECRECY

Article 76 MiFID II - Professional Secrecy

Although not a MiFID firm, we maintain professional secrecy equivalent to Article 76 standards:

**Confidentiality:**

●     All user information treated confidentially

●     Access limited to authorized personnel

●     No disclosure to third parties except:

●     As required by law

●     With user consent

●     To service providers under confidentiality agreements

**Staff Obligations:**

●     All staff bound by confidentiality agreements

●     Training on data protection

●     Prohibition on use of confidential information

●     Consequences for breach

14. COMPLAINTS HANDLING

Article 26 MiFID II - Complaints

**Internal Complaints Procedure:**

**Step 1: Submit Complaint**

●     Email: tradeoracle@proton.me

●     Subject: "EU Complaint - [Your Name] - [Member State]"

●     Include:

●     Account details

●     Nature of complaint

●     Date(s) of incident

●     Desired resolution

●     Supporting documents

**Step 2: Acknowledgment**

●     We will acknowledge receipt within 3 business days

●     Provide reference number

●     Indicate expected response timeframe

**Step 3: Investigation**

●     Thorough review of complaint

●     Request additional information if needed

●     Fair and impartial assessment

**Step 4: Response**

●     Final written response within 8 weeks

●     Explanation of outcome

●     Reasons for decision

●     Information on further recourse

**Complaint Records:**

●     All complaints logged and tracked

●     Regular review for systemic issues

●     Board-level oversight of complaints

●     Annual complaints reporting

Out-of-Court Dispute Resolution

**EU Online Dispute Resolution:**

●     Platform: https://ec.europa.eu/consumers/odr

●     Facilitates cross-border dispute resolution

●     We commit to participate in good faith

**National ADR Schemes:** You may also have access to Alternative Dispute Resolution schemes in your member state. Check with your national financial regulator for available options.

**Note:** As a non-EU firm, availability of ADR schemes may vary by jurisdiction.

15. PROTECTION OF VULNERABLE CLIENTS

Enhanced Care

If you identify as a vulnerable client due to:

●     Advanced age or youth

●     Physical or mental health conditions

●     Financial difficulties

●     Low financial literacy

●     Limited language proficiency

●     Recent bereavement or life changes

**We urge you to:** 1. Reconsider whether this service is appropriate 2. Seek professional financial advice before proceeding 3. Contact us at tradeoracle@proton.me for additional support 4. Have a trusted person review materials with you

Gambling-Related Concerns

Derivative trading can become problematic. Warning signs:

●     Trading with money you cannot afford to lose

●     Chasing losses by increasing position sizes

●     Trading compulsively or emotionally

●     Hiding trading activity from family

●     Borrowing to fund trading

●     Neglecting other responsibilities

**If you recognize these patterns, please seek help:**

●     Your country's problem gambling helpline

●     Mental health professionals

●     Financial counseling services

**We will:**

●     Terminate accounts showing problematic patterns (at our discretion)

●     Provide resources for problem gambling

●     Not encourage excessive trading

16. ONGOING OBLIGATIONS AND MONITORING

Service Monitoring

We continuously monitor:

●     Platform reliability and uptime

●     Data accuracy and timeliness

●     Signal generation quality

●     User feedback and complaints

●     Regulatory developments

●     Market conditions affecting service

Updates and Changes

**Service Updates:**

●     Regular enhancements to algorithms

●     Platform improvements

●     New features and tools

●     Bug fixes and performance optimization

**Regulatory Updates:**

●     Monitor MiFID II developments

●     Review national regulations

●     Update disclaimers as needed

●     Enhance compliance procedures

**Communication of Changes:**

●     Material changes notified by email

●     Posted on platform login

●     Reasonable advance notice provided

●     Option to cancel if changes unacceptable

17. RECORD KEEPING

Article 16 MiFID II Principles Applied

Although not required (as we're not a MiFID firm), we maintain records:

**User Records:**

●     Account creation and verification

●     Subscription history and payments

●     Service usage and access logs

●     Communications with users

●     Complaints and resolutions

**Business Records:**

●     Platform performance metrics

●     Algorithm development and testing

●     Risk assessments and reviews

●     Policy and procedure documents

●     Regulatory correspondence

**Retention:**

●     Minimum 5 years as per MiFID II standards

●     Longer where required by law

●     Available for regulatory inspection (if applicable)

18. MARKET ABUSE REGULATION

MAR Compliance

**No Inside Information:**

●     We have no access to inside information about issuers

●     All analysis based on publicly available data

●     No material non-public information used

**No Market Manipulation:**

●     We do not engage in manipulative trading practices

●     Signals are genuine technical analysis

●     No wash trades, layering, spoofing, or other manipulation

●     No dissemination of false information

**User Obligations:**

●     You are responsible for compliance with MAR

●     You must not use our service for market abuse

●     You must not trade on inside information

●     You must not engage in manipulative practices

**Reporting:** If you become aware of potential market abuse through our platform, report to your national competent authority.

19. ANTI-MONEY LAUNDERING (AML)

AML Compliance

As a U.S. company, we comply with U.S. anti-money laundering laws. We also implement reasonable measures consistent with EU standards:

**Customer Due Diligence:**

●     Identity verification at registration

●     Screening against sanctions lists

●     Monitoring for suspicious activity

●     Enhanced due diligence for high-risk users

**Prohibited Users:**

●     Persons on EU sanctions lists

●     Persons from high-risk jurisdictions

●     Politically Exposed Persons (unless approved)

●     Persons engaged in money laundering

**Suspicious Activity:** We will report to U.S. authorities and may cooperate with EU authorities regarding:

●     Unusual subscription patterns

●     Attempts to use service anonymously

●     Connection to known criminal activity

20. TAXATION

Tax Implications

**We Do Not Provide Tax Advice.**

Derivative trading has tax consequences in all EU member states. You are responsible for:

●     Understanding applicable tax laws

●     Reporting trading activity

●     Paying taxes on gains

●     Claiming losses (where permitted)

●     Complying with anti-avoidance rules

**Common Tax Issues:**

●     Capital gains tax on profits

●     Ordinary income tax (in some jurisdictions)

●     Transaction taxes (where applicable)

●     VAT on subscription fees (if applicable)

●     Cross-border tax considerations

**DAC6 Reporting:** If applicable in your jurisdiction, be aware of mandatory disclosure rules for certain tax arrangements.

**Seek Professional Advice:** Consult a tax advisor familiar with:

●     Your member state's tax laws

●     Derivative trading taxation

●     Cross-border issues

●     Reporting requirements

21. LANGUAGE

Working Languages

This service is primarily provided in English. Documents are available in English, with translations into [other languages] for convenience.

**In case of discrepancy:** The English version prevails.

**Your Language Rights:**

●     You may communicate with us in your national language

●     We will make reasonable efforts to respond appropriately

●     Material communications available in major EU languages (upon request)

22. APPLICABLE LAW AND JURISDICTION

Governing Law

For users resident in the European Union, this disclaimer and any disputes shall be governed by:

●     The laws of [YOUR CHOSEN EU MEMBER STATE], OR

●     The laws of the user's member state of residence

This does not affect mandatory consumer protection laws in your jurisdiction.

Jurisdiction

Disputes may be brought in courts of:

●     Your member state of habitual residence, OR

●     [YOUR CHOSEN EU MEMBER STATE, if you have establishment there]

This does not limit any mandatory jurisdiction rules under EU law (Brussels Ia Regulation).

Consumer Rights

Nothing in this section limits your statutory rights as a consumer under EU law, including:

●     Consumer Rights Directive (2011/83/EU)

●     Unfair Contract Terms Directive (93/13/EEC)

●     National consumer protection laws

23. WITHDRAWAL RIGHTS

Consumer Contracts Directive

As an online service provided to consumers, you may have withdrawal rights under the Consumer Rights Directive:

**14-Day Cooling Off Period:**

●     Right to cancel within 14 days of subscription

●     No reason required

●     Full refund (minus any processing fees as stated in main terms)

**Exception - Commencement of Services:** If you request services begin immediately (by actively using the platform), you acknowledge that:

●     The 14-day period may not apply (depending on national law)

●     Refund may be prorated for services provided

**How to Withdraw:** Email tradeoracle@proton.me with:

●     "Withdrawal" in subject line

●     Your name and account details

●     Date of subscription

**Refund Timeline:**

●     Within 14 days of withdrawal notice

●     Via original payment method

●     No penalty charges (except disclosed processing fees)

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24. PROHIBITED USES

Users must not use this service for:

●     Market manipulation or abuse

●     Money laundering or terrorist financing

●     Insider trading

●     Front-running or trading ahead

●     Violations of sanctions or export controls

●     Circumventing trading restrictions

●     Any illegal purpose

Violation results in immediate termination and potential reporting to authorities.

25. FORCE MAJEURE

We are not liable for failure to perform due to:

●     Natural disasters

●     War, terrorism, civil unrest

●     Government actions or sanctions

●     Power outages or telecommunications failures

●     Strikes or labor disputes

●     Pandemics or public health emergencies

●     Other events beyond reasonable control

26. SEVERABILITY AND ENTIRE AGREEMENT

**Severability:** If any provision is held invalid, remaining provisions continue in full force.

**Entire Agreement:** This disclaimer, together with main terms and privacy policy, constitutes entire agreement regarding this service.

**Priority of Documents:** In case of conflict: 1. This EU-Specific Disclaimer 2. Main Disclaimer and License Agreement 3. Privacy Policy

27. CONTACT INFORMATION

**EU Queries:** Email: tradeoracle@proton.me

**U.S. Headquarters:** Trade Oracle Group 2489 W Main St. Littleton, CO 80120

**EU Establishment:** 12 Hay Hill, Mayfair London (UK) W1J8NR

FINAL ACKNOWLEDGMENT

By using TradeOracle.com services from the European Union, you acknowledge that:

✓ You have read and understood this EU-Specific Disclaimer ✓ You understand this is not a MiFID II-regulated service ✓ You are not entitled to MiFID II investor protections ✓ You understand the risks of trading derivatives ✓ You will not hold us responsible for trading losses ✓ You have assessed appropriateness for your circumstances ✓ You have the financial capacity to bear losses ✓ You have sought or declined to seek professional advice ✓ You understand our service limitations ✓ You accept these terms voluntarily

**Document Version:** 1.0 **Last Updated:** 26 December 2025 ** MiFID II best practices applied voluntarily to non-regulated service