Legal Documents for 9Cents

Trading Compliance & Fair Practice Guidelines

At 9Cents Financials Ltd., we are dedicated to providing a secure, transparent, and efficient trading environment through our advanced and highly secured MT5 trading platform. As part of our commitment to maintaining a fair and compliant trading ecosystem, we kindly remind all clients, traders, Introducing Brokers (IBs), and affiliate members to adhere to our Trading Terms & Conditions and Guidelines on Do’s and Don’ts when executing trades or utilizing Expert Advisors (EAs) on our platform.

Trading Guidelines & Compliance Measures

To uphold fair trading practices, 9Cents Financials Ltd. strictly prohibits any form of abusive, manipulative, or illicit trading activities. Any account found engaging in such practices will be subject to disciplinary actions, including but not limited to trade nullification, account suspension, or deposit forfeiture.

Key Trading Guidelines:

• Trade Validity: A trade must remain open for a minimum of 180 seconds to be considered valid.
• Trading Gaps: A minimum gap of 180 seconds must be maintained between the buying and selling of the same instrument.
• Prohibition on Cross-Trading: Trading the same instrument in both spot and futures markets within the same account is strictly prohibited.
• Scalping & Manipulative Trading: Any detection of abusive scalping or coordinated trading patterns across multiple accounts may result in account suspension and deposit forfeiture.
• Swap-Free Policy Abuse: If misuse of the swap-free policy is identified, backdated swap charges may be applied, or affected trades may be nullified.

Prohibited Trading Practices:

• Pip Hunting: Profits obtained from pip hunting in commodities or forex will be removed without prior notice.
• Credit Abuse: Any misuse of credit facilities will result in the removal of associated profits.
• Rebate Violations: Rebates will not be credited if trading activity is found to violate company policies.

Regulatory Compliance & Commitment

At 9Cents Financials Ltd., we adhere strictly to the regulatory standards set forth by relevant authorities to ensure a safe, transparent, and ethical trading environment for all our clients.

We appreciate your trust and cooperation in maintaining the integrity of our trading ecosystem. Our commitment remains unwavering in delivering seamless, efficient, and secure brokerage services to traders worldwide.

For any inquiries or further clarifications, please feel free to contact our support team.

Trade responsibly, trade with confidence.

Terms & Conditions*

1. Introduction

These Terms & Conditions ("Agreement") govern the relationship between you ("Client") and 9Cents Financials Ltd. ("Company") regarding the use of the Company’s trading services, including but not limited to trading accounts, platforms, and related financial services.

By opening an account, executing trades, or otherwise using the Company’s services, the Client acknowledges and agrees to be bound by these Terms & Conditions*.

2. General Trading Terms

2.1. Account Eligibility

• Clients must be at least 18 years old and legally authorized to enter into binding agreements.
• The Company may, at its sole discretion, refuse to open an account or provide services without obligation to provide a reason.

2.2. Trading Platform & Execution

• The Company provides trading services via the MT5 trading platform.
• The Client acknowledges that market execution, spreads, leverage, and order processing are subject to liquidity conditions and may vary.

2.3. Fair Trading Practices

• Clients must adhere to fair trading practices and refrain from engaging in:
  1. Abusive, manipulative, or illicit trading activities.
  2. Latency arbitrage, pip hunting, or excessive scalping that exploits the system.
  3. Cross-trading of spot and futures instruments within the same account.
• The Company reserves the right to suspend accounts, and/or nullify trades, and/or forfeit deposits in case of trading policy violations.

3. Swap-Free Trading Conditions

3.1. Eligibility & Request Process

• Swap-free trading is available for clients who cannot pay or receive swaps due to religious beliefs.
• By requesting a swap-free account, the Client confirms understanding and acceptance of this section.
• The Company reserves the right to request proof to justify the request.
• Approval of a swap-free account is at the Company’s discretion, and the Company may deny or revoke the status without providing a reason.
• Once approved, all of the Client’s accounts will be converted to swap-free.

3.2. Applicable Instruments & Swap-Free Periods

Asset Classes	Swap-Free Duration
Forex Majors & Crosses	No restriction
Precious Metals	No restriction
Commodities (Non-Futures)	Up to 10 days
Cryptocurrencies	Up to 10 days
FX Exotics	Up to 3 days
Indices – Spot & Futures	No restriction

• A detailed list of swap-free instruments is available and subject to periodic updates.

3.3. Administrative Fees

• Positions exceeding the swap-free grace period will be subject to a daily administrative fee, recorded in the Client’s account as "Admin Fee".
• These fees may impact account equity and margin requirements.

4. Deposits, Withdrawals & Processing Time

4.1. Deposits & Withdrawals

• The Client may fund and withdraw from their account using approved payment methods listed on the Company’s platform.
• The Company does not accept third-party payments for security reasons.

4.2. Processing Time

• Transfers and withdrawals typically take up to 24 hours to reflect in the Client’s account.
• The Company reserves the right to request additional verification for security and compliance reasons, which may extend processing times.

5. Prohibited Trading Practices & Compliance

5.1. Prohibited Activities

The following activities are strictly prohibited:

• Pip hunting in forex or commodities (profits obtained this way will be removed).
• Credit abuse (any misuse of credit will result in profit removal).
• Rebate violations, including:
  1. Wash trading (opening opposing positions to generate fake trading volume).
  2. Collusion between accounts to manipulate rebates.
  3. Affiliate abuse, where Introducing Brokers (IBs) or partners generate artificial trading activity.

5.2. Consequences of Violations

If any fraud, abuse, or manipulation is detected, the Company reserves the right to take the following actions without prior notice:

• Revoke swap-free status and apply backdated swaps.
• Recover unaccrued swaps, interest, or administrative costs.
• Suspend or terminate the Client’s accounts, voiding affected trades and profits.
• Withhold rebates or commissions from IBs found violating policies.

5.3. Regulatory Compliance

• The Company adheres to regulatory standards and may implement additional compliance measures at its discretion.
• Swap-free accounts are subject to periodic reviews to ensure compliance.

6. Risk Disclosure & Acknowledgment

6.1. Market Risks

• The Client acknowledges that trading forex and CFDs carries significant risk, and they may lose more than their initial deposit.
• The Company does not guarantee profits and is not liable for losses due to market fluctuations.

6.2. Overnight Charges & Adjustments

• The Company reserves the right to charge fees for overnight positions if deemed necessary.
• Any rollover fees applied to non-swap-free instruments will be charged accordingly.

7. Governing Law & Legal Framework

7.1. Jurisdiction

• This Agreement shall be governed by and construed in accordance with the laws of United Arab of Emirates.
• Any disputes shall be resolved under the exclusive jurisdiction of the relevant courts.

7.2. Binding Agreement

• The Client Agreement remains an integral part of these Terms & Conditions*.
• Any matters not covered herein shall be governed by the provisions of the Client Agreement.

7.3. Language & Interpretation

• These Terms & Conditions may be translated into multiple languages.
• In the event of any inconsistency, the English version shall prevail.

8. Amendments & Updates

8.1. Right to Modify

• The Company reserves the right to update, modify, or revise these Terms & Conditions* at any time without prior notice.
• Clients will be notified of significant changes, and continued use of the trading platform constitutes acceptance of the updated terms.

9. Contact Information

For any questions or further clarifications, please contact us at:

Email: [email protected]

Office Address: 507 Office, Latifa Towers, Sheikh Zayed Road, Trade Center 1, Dubai

Risk Warning

1. Introduction

This Risk Warning provides a summary of the potential risks associated with trading Contracts for Difference ("CFDs"). However, it does not disclose all risks or other significant aspects of CFD trading. Before engaging in such transactions, you should ensure that you fully understand the nature of CFDs, the contractual obligations you are entering into, and the extent of your exposure to risk.

CFD trading may not be suitable for all investors. You should carefully consider whether trading CFDs aligns with your investment objectives, financial situation, trading experience, and risk tolerance. If you are uncertain about the risks, it is advisable to seek independent financial advice.

2. Leveraged CFD Trading

2.1. Effect of Leverage

• CFD trading is highly leveraged, which means that leverage can amplify both profits and losses. You may sustain a total loss of your initial margin deposit, and any additional funds deposited to maintain your position.
• If the market moves against your position, you may be required to deposit substantial additional funds on short notice to maintain your open positions. Failure to do so may result in the forced liquidation of your positions at a loss, and you will be liable for any resulting deficit in your account.

2.2. Market Volatility and Margin Calls

• CFDs are highly volatile instruments, and even small market movements can result in substantial losses. If your margin balance falls below the required level, you may be subject to margin calls. The Company may liquidate your positions without prior notice if you fail to meet margin requirements.

3. Risk-Reducing Orders and Strategies

The use of risk management tools, such as stop-loss orders (where permitted), does not guarantee protection against losses. Market conditions may prevent the execution of these orders at the desired price, leading to greater losses than anticipated.

Additionally, strategies involving multiple positions, such as spreads and straddles, may carry risks comparable to taking outright long or short positions.

4. Market Conditions, Trading Restrictions, and Pricing Risks

4.1. Suspension or Restriction of Trading

• Market conditions, such as liquidity shortages or regulatory intervention, may restrict or suspend trading in certain instruments. If a market is closed or suspended, you may be unable to open, close, or liquidate positions, resulting in significant financial losses.

4.2. Deposited Cash and Property

• Funds or assets deposited for trading may not be fully protected, particularly in cases of insolvency or bankruptcy of your counterparty. The extent of your ability to recover funds will depend on applicable laws, regulations, and the specific protections in place.

5. Costs, Fees, and Financial Implications

5.1. Commissions and Charges

• Before you begin trading, you should obtain a clear explanation of all commissions, fees, spreads, and other charges. These costs will directly affect your net profit or increase your overall loss.

5.2. Pricing Risks

• The profit or loss on CFD transactions is directly influenced by market price fluctuations. Prices may be impacted by liquidity, volatility, and economic factors, which could result in losses beyond your initial investment.

6. Principal’s Market and Counterparty Risk

6.1. 9Cents as a Counterparty

• CFDs offered by 9Cents Financials Ltd. are traded in over-the-counter (OTC) markets. As a broker and dealer in CFDs, 9Cents may act as the counterparty to your transactions. As a result, transactions will be executed at prices determined by 9Cents, which may differ from prices available through other dealers or financial institutions.

6.2. System and Execution Risks

• The Company's trading facilities rely on electronic systems, including computer-based order routing and execution systems. As with any electronic system, these platforms are susceptible to temporary disruption, failure, or cyber threats. In the event of system failures, latency, or connectivity issues, orders may be delayed, executed at an unintended price, or not executed at all.
• Your ability to recover losses due to system malfunctions or errors is subject to liability limitations outlined in the Client Agreement and the Online Services & Electronic Trading Agreement.

7. Off-Exchange Transactions and Liquidity Risks

7.1. Off-Exchange Transactions

CFD transactions are executed over-the-counter (OTC) and do not occur on regulated exchanges. This means that:

• Liquidity and pricing may vary, making it difficult to assess fair market value.
• It may be difficult or impossible to close a position, especially during periods of extreme market volatility.
• The counterparty to your trade is typically the broker (9Cents Financials Ltd.), which may impact execution and pricing.

Before engaging in CFD trading, you should fully understand the specific rules, policies, and risks associated with OTC transactions.

8. Electronic Trading Risks

Electronic trading differs from open outcry and other traditional market forms. If you engage in transactions through an electronic trading system, you are exposed to risks including:

• Hardware and software failures, which may result in orders not being executed as intended or not being executed at all.
• Connectivity issues or server downtimes, which may cause disruptions in trade execution.
• High market volatility, which may lead to order slippage and execution delays.

It is the Client’s responsibility to ensure proper internet connectivity and system compatibility to mitigate these risks.

9. Acknowledgment and Final Considerations

By engaging in CFD trading with 9Cents Financials Ltd., you acknowledge and understand that:

• Trading CFDs involves a high level of risk, and you may lose more than your initial deposit.
• The use of leverage can magnify both gains and losses, increasing exposure to market risks.
• Market conditions, system failures, and liquidity constraints may impact your ability to execute trades as expected.
• 9Cents Financials Ltd. does not provide investment, tax, or legal advice. You should seek independent financial advice before trading if necessary.

This Risk Warning forms an integral part of the Client Agreement and should be read alongside other legal documents provided by the Company.

10. Contact Information

For further inquiries regarding this Risk Warning or your trading activities, please contact us at:

Email: [email protected]

Registered Address: 507 Office, Latifa Towers, Sheikh Zayed Road, Trade Center 1, Dubai

Conflict of Interest Management Policy

1. Introduction

9Cents Financials Ltd. ("9Cents" or the "Company") is committed to maintaining the highest standards of integrity, fairness, and transparency in its operations. To achieve this, the Company has implemented a Conflict of Interest Management Policy designed to identify, prevent, and manage potential and existing conflicts of interest that may arise between:

• The Company and its clients
• Clients and other clients

The objective of this policy is to ensure that all clients are treated fairly and without bias, and that conflicts of interest do not negatively impact client interests.

2. Identification and Management of Conflicts of Interest

9Cents undertakes the following measures to effectively identify and manage conflicts of interest:

2.1. Identification of Conflicts of Interest

• Regularly assessing and identifying current and potential conflict of interest situations.
• Evaluating any transaction or service that may create a conflict of interest between the Company and its clients, or between one client and another.

2.2. Disclosure of Conflicts of Interest

• 9Cents will disclose any conflict of interest to clients, either in general terms or specifically in relation to a particular transaction.
• Clients will be informed of any potential impact such conflicts may have on their transactions.

2.3. Prohibition of Conflicting Actions

• If 9Cents is unable to effectively manage or mitigate a conflict of interest, the Company will refrain from undertaking any action that may compromise the fair treatment of a client.
• The Company ensures that all financial services are provided in a manner that maintains fairness and neutrality.

2.4. Protection Against Misuse of Company Funds

• Partners, executives, and employees are strictly prohibited from exploiting 9Cents’s funds in any manner, including but not limited to:
  1. Unauthorized withdrawals
  2. Unauthorized financing or lending
  3. Unapproved fund transfers
  4. Any other action unrelated to the Company’s core financial activities

3. Measures to Mitigate Conflicts of Interest

9Cents has implemented comprehensive organizational and technical safeguards to minimize and manage conflicts of interest. The following measures have been adopted:

3.1. Spatial Separation of Departments

• Departments or divisions that engage in different financial activities are physically separated.
• Access to each department is secured through appropriate security measures to prevent:
  1. Unauthorized personnel from accessing sensitive data or information.
  2. Unauthorized individuals from entering restricted areas.

3.2. Organizational Separation of Duties

• Employees working in specific financial activities are restricted from engaging in other financial activities unless explicitly authorized.
• No employee shall perform duties in a different department or division unless their involvement does not create a conflict of interest.
• Any exceptions are subject to strict review and approval to ensure compliance with regulatory standards.

3.3. Technical Safeguards and System Access Control

• Strict access controls are applied to technical systems to ensure that employees only access systems necessary for their designated roles.
• Employees engaged in a specific financial activity are restricted from accessing systems related to other financial activities for which 9Cents is licensed.
• Access to other systems is only granted in cases of:
  1. Inquiry purposes
  2. Generating specific reports
  3. Other justifiable operational needs
• System access is structured to prevent unauthorized data exposure that may result in conflicts of interest.

4. Compliance and Enforcement

• All employees, executives, and partners are required to comply with this Conflict of Interest Management Policy.
• Any breach or failure to comply with these policies may result in disciplinary action, which may include: 
  1. Suspension or termination of employment
  2. Legal or regulatory consequences, where applicable

9Cents remains committed to maintaining a fair and transparent financial environment by continuously reviewing and enhancing its Conflict of Interest Management framework in alignment with regulatory requirements and industry best practices.

5. Contact Information

For any inquiries or concerns regarding this policy, please contact:

Email: [email protected]

Registered Address: 507 Office, Latifa Towers, Sheikh Zayed Road, Trade Center 1, Dubai

Privacy Policy

1. Introduction

At 9Cents Financials Ltd. ("9Cents", "we", "us", or "our"), we are committed to protecting your privacy and ensuring the security of your personal data. This Privacy Policy outlines how we collect, use, disclose, and safeguard your personal information when you visit our website or use our services.

By accessing our website or using our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and processing of your personal data as described herein.

2. Important Information and Contact Details

For any inquiries regarding this Privacy Policy or our data protection practices, please contact us at:

• Email: [email protected]
• Registered Address: 507 Office, Latifa Towers, Sheikh Zayed Road, Trade Center 1, Dubai
• Contact Us: https://9cents.com/contact

3. Data We Collect About You

We may collect, store, and process the following categories of personal data:

3.1. Identity Data

• Full name, username, date of birth, gender.

3.2. Contact Data

• Billing address, email address, telephone numbers.

3.3. Financial Data

• Bank account details, payment card details.

3.4. Technical Data

• IP address, browser type and version, time zone setting, operating system, and platform.

3.5. Profile Data

• Username and password, purchases/orders, interests, preferences, feedback, and survey responses.

3.6. Usage Data

• Information regarding how you use our website, products, and services.

3.7. Marketing & Communications Data

• Preferences regarding receiving marketing communications from us and your communication preferences.

4. How We Collect Your Data

We collect personal data through the following methods:

4.1. Direct Interactions

• When you fill out forms, create an account, or communicate with us via email, phone, or other channels.

4.2. Automated Technologies

• Data collected through cookies, server logs, and other tracking technologies when you interact with our website.

4.3. Third Parties & Public Sources

• We may receive personal data from service providers, regulatory authorities, business partners, or publicly available sources.

5. How We Use Your Personal Data

We process your personal data only when legally permitted. The purposes for which we process your personal data include:

• Registering you as a new client and managing your account.
• Processing transactions and delivering services.
• Communicating with you regarding our services and responding to inquiries.
• Ensuring compliance with legal and regulatory obligations.
• Improving our website, products, and services through analytics and user feedback.
• Conducting marketing and promotional activities, subject to your consent and preferences.

6. Disclosure of Your Personal Data

We do not sell or rent your personal data. However, we may share your data with:

• Affiliates and subsidiaries within the 9Cents group.
• Service providers and business partners who process data on our behalf.
• Legal, financial, and professional advisors for compliance and risk management purposes.
• Regulatory authorities and law enforcement agencies where required by law.
• Any other parties where you have provided consent or where disclosure is required for operational necessity.

Data Security

We implement appropriate technical and organizational security measures to prevent unauthorized access, loss, misuse, or alteration of your personal data. Access to personal data is restricted to authorized personnel who require such access for legitimate business purposes.

International Data Transfers

Your personal data may be transferred to, stored, or processed in countries outside your jurisdiction. Where such transfers occur, we ensure that adequate safeguards are in place to maintain the protection of your data in accordance with applicable privacy laws.

Data Retention

We retain personal data only for as long as necessary to:

• Fulfill contractual obligations.
• Comply with legal, tax, and regulatory requirements.
• Resolve disputes and enforce agreements.

Once the retention period expires, personal data is securely deleted, anonymized, or archived as required by law.

10. Your Legal Rights

You have the following rights under applicable data protection laws:

• Right to Access: You may request access to the personal data we hold about you.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data.
• Right to Erasure: You may request the deletion of your personal data where permitted by law.
• Right to Object: You may object to the processing of your personal data under certain circumstances.
• Right to Restriction: You may request the restriction of processing under specific conditions.
• Right to Data Portability: You may request a transfer of your personal data to another service provider.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw your consent at any time.

To exercise any of these rights, please contact us at [email protected].

11. Cookies & Tracking Technologies

Our website uses cookies and similar technologies to:

• Enhance website functionality and user experience.
• Analyze site traffic and user behavior.
• Provide targeted advertisements and marketing messages.

You can manage your cookie preferences through your browser settings. For more details, please refer to our Cookie Policy.

Changes to This Privacy Policy

We may update this Privacy Policy periodically. Any modifications will be posted on this page, and where required, we will notify you through email or other appropriate communication methods.

Last updated: [Feb 24th, 2025]