Terms & Conditions

Updated on May, 2024

These terms and conditions (“Terms”) form a legally binding agreement between the user (“User”, “Users”, “you” or “your” “yourself ”) and Zenit World Ltd. ("Zenit", "we", "us", and "our"). We may also refer to this document as the "Agreement" and you expressly agree to the terms of the Agreement. We will also treat your access to, and continued use of, our Services (our "Services" are explained in clause 4 below) as acceptance of the terms of the Agreement.

Zenit World Ltd. is a company incorporated under the laws of the Autonomous Island of Mwali, Comoros Union, with registration number HT00224006 and registered office located at Bonovo Road, Fomboni, Island of Moheli, Comoros Union. Zenit is authorized by the international brokerage and clearing house license number BFX2024011, issued by the Mwali International Services Authority in Comoros Union, in accordance with the International Business Companies Act 2014 and the Brokerage Act 2013, to offer Forex, CFD, Crypto, and Copy Trading (the “Trading Services”) to customers through its centralized exchange (CEX) trading platform (the “Platform”).

For the purpose of these Terms, the Zenit Website, Platform, and any mobile Application (App) shall be considered synonymous, and shall hereinafter simply be referred to as the “Platform”, unless stated otherwise in a particular section of these Terms.

By accessing, using, or clicking the “Sign Up” button on the Platform and/or using our products and services (“Services”), you agree and acknowledge that you have read, understood, and accepted all of the Terms stipulated herein, together with any additional documents or terms referred to.

If you do not understand and accept these Terms in their entirety, you should not register for a Zenit Account and you should refrain from using the Platform and any Services offered by us.

You are responsible for checking our website periodically in order to review the most up to date version of these Terms. Please contact us if you have any questions at [e-mail].

These Terms may be made available in several languages; all versions are legally binding, but in the event of inconsistency between the English language version and the translated version, the English version shall prevail.

Legal requirements in various countries and internal regulatory and client acceptance policies may restrict the Services offered by us. Therefore, certain features in the Platform, and some Services, our campaigns, and promotions, may not be available, or may be restricted, in certain jurisdictions, countries, areas, or regions, or to certain Users to whom such restrictions apply. It is your sole responsibility to remain informed and observe any restrictions and/or requirements imposed with respect to your access to and use of the Platform and our Services. We reserve the right to change, modify, or impose additional restrictions with respect to the access to, and use of the Platform, and/or our Services, or to cancel the access from time to time, at our sole discretion without notification.

Zenit does not provide personal financial advice. We may provide factual information, information about transaction procedures, and information about the potential risks, however, your use of our Services shall

be at your sole discretion and risk. No communication or information provided to you by us is intended as, or shall be considered or construed as, investment advice, financial advice, trading advice, legal advice, or any other sort of advice or inducement. You are solely responsible for determining whether any trade, trading strategy, or related transaction is appropriate for you according to your personal means, financial circumstances, and risk tolerance.

1. DEFINITIONS

1.1. Capitalized terms not otherwise defined in these Terms will have the following meanings:

1.1.1. “Account” refers to an account on the Zenit Platform opened and held in the name of the User and maintained by us.

1.1.2. “Arbitration” refers to a formal process of settling a dispute between parties before an arbitral tribunal, and includes any arbitration mutually agreed by both parties.

1.1.3. “Authorized Person” refers to any natural person appointed by a legal entity under a Letter of Authorization and/or Power of Attorney to (a) represent and sign in, (b) open an Account, and;

(c) carry out transactions on our Platform on behalf of the legal entity. This is likely to apply to our institutional Users.

1.1.4. “Business Transferee” has the meaning given to it in section 20 of these Terms.

1.1.5. “CFDs” refers to Contracts for Difference, which are a derivative financial instrument where Users can speculate on the future movement of a market or asset’s underlying price. CFDs are not permitted in the US.

1.1.6. “Churning” refers to the illegal and unethical practice by a broker of excessively trading assets in a User’s Account in order to generate commission.

1.1.7. “Derivative Services” refers to all the financial services and activities related to the Derivative Products.

1.1.8. “Derivative Products” are the OTC financial contracts set between two or more parties that derive their value from an underlying asset, group of assets, or benchmark.

1.1.9. “Fees” refers to the fees, costs and charges payable to us in relation to the transactions and/or your access to and use of the Services. These Fees are published on the Platform and are subject to change at our sole discretion.

1.1.10. “False Trading” refers to where a person intentionally, negligently, or recklessly, does or causes anything, to affect or is likely to affect by creating a false or misleading appearance of active trading in a Virtual Asset or creating an artificial price for a Virtual Asset.

1.1.11. “Front-running” refers to the process when someone uses technology or market advantage to get prior knowledge of upcoming Transactions. This might also be known as slow matching.

1.1.12. “GDPR” refers to the General Data Protection Regulation, which is a regulation of the European Union. If your country of residence is based within the European Economic Area (EEA), the GDPR applies to our processing of your Personal Data (within the meaning of the

GDPR). If your country of residence is outside of the EEA, provisions related to the GDPR shall not apply to your use of our Services.

1.1.13. “Institutional Client” refers to a User who is an Authorized Person of a corporate entity, acting on behalf of the corporate entity.

1.1.14. “Personal Data'' refers to any information in respect of commercial transactions which: (i) is being processed wholly or partly by means of equipment operating automatically in response to instructions given for that purpose; (ii) is recorded with the intention that it should wholly or partly be processed by means of such equipment; or (iii) is recorded as part of a relevant filing system or with the intention that it should form part of a relevant filing system, that relates directly or indirectly to a data subject, who is identified or identifiable from that information, or from that and other information in the possession of a data user, including any sensitive Personal Data and expression of opinion about the data subject.

1.1.15. “Platform” is the collective term which refers to the Zenit website, online trading exchange platform, mobile phone application, and any other application programming interface (API), as may be used from time to time, creating a virtual environment within which, the software powering the exchange can be run from, for Users to access the Services.

1.1.16. “Insider Dealing” refers to an illegal activity in which a person who has access to non-public, material information about an exchange, company, or Virtual Asset utilizes that information to make advantageous trades and discloses the inside information directly or indirectly to another person.

1.1.17. “Letter of Authorization” refers to a letter provided by any legal entity that attests that the individual completing the KYC application has the legal authority to open a corporate Account on our Platform, sign in, and carry out transactions on behalf of the legal entity. Such letters shall be signed, stamped, and dated (must not be less than 3 months old). The letter shall include the legal entity’s full registered legal name and the full name of the UBO/Manager/Director/Chairman, who is authorizing the “Authorized Person”.

1.1.18. “Levy of Interest Period” refers to the 24 hour period outlined in clause 5.4.12, during which interest is not payable.

1.1.19. “Market Manipulation” refers to an activity that attempts to artificially influence a Virtual Asset’s price or the behavior of the markets. Any single individual or group of people may create an illusion in the market in order to profit from the aftermath.

1.1.20. “OTC” refers to over-the-counter and refers to trades that are made on a decentralized exchange platform.

1.1.21. “Pending Dues” refers to the amounts payable by the User to Zenit, as shown in the User’s Account. Such payments shall include but not be limited to, commission, interest charges, liquidation charges.

1.1.22. “Performance Fee” refers to the fee Zenit charges Users in accordance with the details under these Terms.

1.1.23. “Personal Data” has the meaning given to it in our Privacy Policy; any information that relates directly or indirectly to a natural person whether living or deceased, who is identified or identifiable from that information, or from that and other available information.

1.1.24. “Price Rigging” known as price fixing or collusion, which is a form of market manipulation.

1.1.25. “Prohibited Activity or Business” refers to;

1.1.25.1. Any unlawful activity that violates or assists in violation of, any law, statute, ordinance, regulation, or sanctions programs administered in the countries where Zenit conducts business or which would involve proceeds of any unlawful activity; publishing, distributing, or disseminating any unlawful material or information.

1.1.25.2. Any abusive activity such as transmitting or uploading any material on the Platform that contains viruses, trojan horses, worms, or any other harmful programs.

1.1.25.3. Any fraudulent activity that seeks to defraud Zenit, Our Users, or any other person by providing any false, inaccurate, or misleading information to Us.

1.1.25.4. Any Transactions made directly and/or indirectly to any sanctioned individual, sanctioned group, and/or sanctioned jurisdictions.

1.1.25.5. Any activity(s) related to terrorist financing, fraud shops, child abuse, scams, ransomware, a darknet market, unlawful gambling, unlawful Hawal, Pump, and Dumps schemes, Front-running, Wash trading, Spoofing and Layering, Stop Hunting, Churning and Quote stuffing, False trading, and Insider dealing, price rigging and deceptive, Market Manipulation, drug trafficking including chemicals used to manufacture synthetic drug or drugs production of marijuana dispensary, sale of tobacco, e-cigarettes, e-liquid, online prescription or pharmaceutical services, age-restricted goods or services, weapons and munitions, gunpowder and other explosives, fireworks, toxic, inflammable and radioactive materials, sales of narcotics, controlled substances, or any equipment or tools designed for making or using drugs, the sale of a legal substance that provides the same effect as an illegal drug, pornography and other obscene materials, sites offering any services related to prostitution, and sexual-related services, financial risk, legal liability, or violations of any regulations.

1.1.25.6. Any activity in an engagement involving items that infringe or violate any of the copyright, trademark, right of publicity or privacy, or any other proprietary right, name, logo, or brand of Zenit Platform.

1.1.26. “Pump and Dump” refers to a group of people working together to artificially inflate (pump) the value of an asset only to then sell off their interests in the asset (dump), causing the price to plummet.

1.1.27. “Quote Stuffing” refers to the practice of placing an unusual number of buy or sell orders on a particular security and then immediately canceling them.

1.1.28. “RFI” refers to a request for further information, which in the context of these Terms means a legitimate request by Zenit, or a Third Party Partner, in order to establish the potential relationship between you and another third party, to validate your credentials, or to determine the nature of any transaction you have made.

1.1.29. “Spoofing and Layering” refers to both forms of market manipulation whereby a trader uses fake orders to deceive other traders as to the true levels of demand in the market.

1.1.30. “Strategies Profit” refers to the revenue you are getting from a trading strategy.

1.1.31. “Stop Hunting” refers to a strategy that pushes prices in a certain direction to trigger a cascade of stop-loss orders.

1.1.32. “Third Party Partner” refers to any other party, whether an individual or a corporate entity, that is not directly involved in Zenit’s business, but is collaborating with Zenit to provide complementary services and/or features, that are ancillary to the services we provide on our Platform. These Third Party Partners may include software developers, data processors, payment processors, content providers, or any other third party integrating their own services with the Platform, to enhance its functionality and offering to our Users.

1.1.33. “Transaction” refers to any transaction entered on our Platform, including the process of transferring Virtual Assets between two virtual wallets and/or converting any Fiat currency to virtual currency, or vice versa conversions. Transactions may be processed by Third Party Partners.

1.1.34. “Virtual Asset” refers to a cryptographically stored digital representation of value that can be digitally traded, or transferred, and can be used for payment or trading purposes, including cryptocurrencies and tokens.

1.1.35. “Wash Trading” refers to feeding misleading information to the Virtual Asset market where any individual or a group of individuals rapidly buys and sells the same Virtual Asset to inflate the volume artificially.

1.1.36. “Wallet” refers to the cryptographic application that provides Users a means to store, manage and transact their Virtual Assets on the Platform.

1.1.37. “Zen Token” this is the native non-transferable token developed by Zenit. It will be issued on the Polygon network (Matic) and is a deflationary token. The Zen token allows Users to access all the Services and other benefits that are available on the Platform.

2. ELIGIBILITY CRITERIA & GENERAL TERMS

2.1. Eligibility

2.1.1. Retail Client: A User who is a natural person who has attained the age of 18 (eighteen) with legal capacity and has sufficient authorization to enter into these Terms. However, based on Our internal regulatory and User acceptance policies, We may restrict certain citizens or residents of some countries based upon various factors.

2.1.2. Institutional Client: A User who is a corporate entity and has provided sufficient authorization to their Authorized Person to enter into these Terms. The Authorized Person shall submit the Letter of Authorization in order to sign up with our Platform. Due to certain internal regulatory policy decisions of Zenit, we may restrict certain legal entities of some countries. In the event of any changes in the identity of the Authorized Person, the entity shall promptly and without delay notify us in writing. Such notification shall be provided immediately upon the occurrence of any changes to ensure accurate and up-to-date information regarding the Authorized Person.

2.2. Supplementary Terms: These Terms between you and us are not exhaustive in their coverage of all rights and obligations. As a result, the Privacy and Cookies Policy, and any other agreements entered into separately between you and us shall be deemed Supplementary Terms that are fully incorporated into these Terms and carry the same legal effect. These Supplementary Terms are considered integral parts of these Terms, and any provisions or requirements set forth in the Supplementary Terms shall be binding and enforceable in conjunction with the provisions of these Terms.

2.3. Changes to the Terms: Our Terms undergo regular reviews and updates to ensure compliance with applicable laws, regulations and international standards. We retain the right to change or modify these Terms at our sole discretion, at any time, for any reason. Any updated version of the Terms will be promptly made available at the top of the Terms page on our Platform. By continuing to access and use our Platform after an updated version of the Terms has been released, it is understood that you agree and consent to the revised content of the Terms. Therefore, it is strongly recommended that you regularly review these Terms to ensure a clear understanding of the Terms that govern your continued access to, and use of, our Services.

2.4. User Restrictions

2.4.1. Due to internal regulatory and User acceptance policy(s) considerations at Zenit, we have implemented restrictions on conducting business with individuals, legal persons, and entities that (i) do not possess the full legal capacity and adequate authorizations to enter into these Terms as an individual, legal entity, or other forms of organization; (ii) have a history of prior suspension or removal from our Platform; (iii) are situated in, citizens of, or are resident within the United States; (vi) have established or possible connections to predicate offenses and/or sanctions imposed by the Office of Foreign Assets Control (OFAC), European Union (EU), United Nations Security Council (UN), other in-country local lists (including but not limited to sanctions lists and terrorist lists), and other internally restricted countries.

2.4.2. It is strictly prohibited to disseminate your Account credentials to any other third party individual(s) and/or transfer the ownership unless you have obtained our consent prior. Likewise, conducting business transactions in a personal Account (“Business Misuse”) is strictly prohibited. You are fully responsible for all activity that occurs under your Account. We reserve the full right to request further information (“RFI”) where deemed necessary to establish the potential relationship between the beneficiary and the originator and economic rationale behind any transaction(s) and relationship(s).

2.4.3. In the event of any attempt to access unauthorized parts or functions of our Services, violate security or authentication measures, impersonate or manipulate identification, disguise your identity or the origin of messages or transmissions, or use our Services in any illegal manner, we reserve the right to take such actions that we deem necessary including but not limited to suspend the Account temporarily, freezing your Account, reporting the incident to relevant authorities (if applicable), deleting any information, and terminating your Account.

3. ACCOUNT SETUP

3.1. Registration of Zenit Account:

3.1.1. To use our Services, you will be asked to provide your Personal Data, including legal name, date of birth, country of residence, mobile number, email address, and generate a unique and memorable password. You will be asked to confirm that you have read and accepted this Agreement, the Privacy and Cookies Policy, and/or all additional terms and regulations governing the Platform.

3.2. Identity Verification

3.2.1. You will need to comply with our Know Your Customer (“KYC”) procedures before you are permitted to open an Account and access and use our Services, which will be a combination of procedures carried out by us and through a Third Party Partner. All information that you provide must be complete, accurate, and truthful. You must promptly inform us and/or update this information whenever it changes.

3.2.2. If there are reasonable grounds to believe that any of the information you have provided is incorrect, false, outdated, or incomplete, you authorize us to raise an RFI, whether directly or through a Third Party Partner, and to take any action we deem necessary based on the results of such RFI. Further, you expressly consent, acknowledge and understand that your Personal Data may be disclosed to third-party organizations who deal with identity verification, compliance data recordation, credit reference, fraud prevention, or financial crime agencies. You can review our Privacy Policy for more information about how we process your Personal Data and how we share your Personal Data in limited circumstances.

3.2.3. In the event that we are unable to contact you using the contact information you have provided, you will bear full responsibility for any loss or expenses incurred by us during your use of our Services.

3.2.4. We reserve the right to exercise discretion in permitting or denying registration on the Platform. We are under no obligation to accept registrations from all individuals and legal entities. We may refuse, terminate, or suspend registration for anyone at any time without providing a specific reason for doing so. This allows us the flexibility to ensure the integrity, security, and compliance of the Platform and its user base.

3.2.5 We may share your information with Third Party Partner for, but shall not be limited to, compliance with AML Laws, a regulatory request or obligation, for tax reporting

purposes, to investigate suspicious activity or to protect the integrity of the Third Party Partner’s systems. For the avoidance of doubt, the legal basis for sharing this information will be either a) compliance with a legal obligation or b) the legitimate interests of Zenit, depending on the circumstances.

3.2.6 You are responsible for regularly reviewing and updating your information.

3.3. Account Security

3.3.1. We are fully committed to ensuring the security of the funds you deposit with us, and we have implemented industry-standard security measures. We emphasize the importance of safeguarding your Account credentials, including your username and password. Under no circumstances should this information be disclosed to any third-party.

3.3.2. It is your responsibility to protect your Account from unauthorized access. In order to enhance security and mitigate the risk of cybercrime and the loss of Personal Data, we have implemented a two-factor authentication (“2FA”) system. We encourage all Users to enable two-factor authentication to further enhance the security of their Accounts and minimize potential security vulnerabilities. In order to circumvent loss, misuse, unauthorized acquisition, or alteration of Personal Data, Users are requested to choose the strongest password and to protect the Account from any third parties. You also agree to be solely responsible for taking the necessary security measures to protect your Account and Personal Data and information.

3.3.3. In the event of any unauthorized access to your Account, we strongly urge you to notify our customer support team immediately. Zenit will never, under any circumstances, request your password, passphrase, or account information. We assume no responsibility for any losses you may incur as a result of compromised Account login credentials or failure to act upon notices or alerts that we may send you provided that such compromise is not due to any fault on our part.

4. USE OF OUR PLATFORM

4.1. By registering for an Account and accepting these Terms, Zenit shall grant you a non-exclusive, non-transferable, revocable license to use the Platform and Services in accordance with these Terms.

4.2. To access your Account, you must have the necessary equipment with the required software (such as a suitable computer or smartphone), and access to the internet, which you are solely responsible for maintaining. If using a mobile application (“App”), your use of the App remains at all times subject to the terms and conditions and privacy policies of the relevant App store from which You downloaded it, for example, Google Play or Apple App Store. To the extent that there is a conflict between those terms and conditions and these Terms, these Terms shall prevail.

4.3. Certain Services or parts of the Platform may be accessible only by agreeing to the terms and conditions and privacy policies of our Third Party Partners. We strongly encourage you to read the terms and conditions and privacy policies before accessing the platforms or services of our Third

Party Partners (“Third Party Partner Platforms''). Please find our Third Party Partners list attached to this document.

4.4. We reserve the right to change, suspend, or discontinue any aspect of the Services at any time and in any jurisdiction, including hours of operation or availability of any feature, without liability to you.

4.5. During periods of significant volatility or high volume, access to our Services may experience degradation or become unavailable. As a result, there may be instances where buying or selling transactions cannot be executed, and there could be delays in support response times. Please be aware that we shall not be held liable for any losses that may arise from or be attributed to transaction delays during such periods. It is advisable to consider this possibility and exercise caution when engaging in transactions during increased volatility or volume.

You are referred to our Risk Disclosure for further information of the risks involved in connection with your access to Platform.

5. OUR SERVICES

5.1. We, together with our Third Party Partners, offer a wide range of Derivative Products and Services to our Users, including but not limited to primary Services such as trading, staking, savings, and some other value-added Services such as P2P, swaps, referral and promotional programs (collectively referred to as "Services'').

5.2. Trading and engaging in Virtual Asset-related activities carry inherent risks, including but not limited to market volatility, regulatory uncertainties, and potential loss of your funds. You acknowledge and accept that you have carefully considered and understand these risks before participating in our Services. Zenit has made available a Risk Disclaimer that provides a comprehensive overview of the risks associated with the usage of our Services. By using our Services, you confirm that you have read, understood, and agreed to the terms outlined in the Risk Disclaimer, which is incorporated by reference into these Terms.

5.3. You acknowledge that our Platform is solely designed to provide access to our Services. It is your responsibility to thoroughly verify the authenticity, legality, and validity of any Virtual Assets, financial instruments, Derivative Products, or information pertinent to your transactions.

5.4. Trading

5.4.1. Spot Trading - Spot Trading is the process of buying and selling Virtual Assets at real-time prices with the aim of generating a trading profit.

5.4.2. Copy Trading - We offer a competitive Copy Trading Service which allows Users to automatically copy positions opened and managed by other traders on our Platform. You are free to select which portfolios of top-performing traders you would like to copy and by doing so you can leverage their experience and learn from their trading behavior. Zenit accepts no liability for the performance of Copy Trades.

5.4.3. P2P Trading – We offer P2P (Peer-to-Peer) Trading Services, which allow Users to directly buy or sell Virtual Assets with other Users on the platform, without the involvement of

intermediaries.

5.4.4. Future Trading - By participating in a Future contract you enter into an agreement to buy or sell an asset at a future date for a fixed price. Generally, it is used to lock in profits when trading in volatile markets. As a future trader, you acknowledge and agree that you shall access and use the Futures Trading Services at your own risk and you will be solely responsible for any trading/non-trading activity in our Platform. You shall not enter into any Transactions or invest in funds that are above your financial abilities. Failure to maintain a sufficient amount of assets in your Account can result in insolvency of assets in your future Account and hereby, you agree and consent to maintain your Account a sufficient amount of Virtual Assets required by us to engage in Future Trading. You acknowledge and agree to trade in good faith. In the event we suspect your Account to be in violation of these Terms, we shall have the right to immediately suspend, freeze, or lock the Virtual Assets in your Account. You acknowledge and agree to conduct all Futures Trading on your own Account and claim full sole responsibility for your own decisions and activities. We shall not take any responsibility for any losses or damages incurred as a result of your use of any Services or your failure to understand the risks associated with Virtual Assets. You acknowledge and agree that you fully understand the high risk of Futures Trading and you have read and understood all these Terms.

5.4.5. Exchange-Traded Funds (the “ETF”) - We offer the ETF Service, which is a financial tool that follows the trend of a market or a group of markets. With this, it is possible to execute a trade that allows market participants to buy baskets of stocks containing shares of hundreds or thousands of companies with a single purchase.

5.4.6. Buy/Sell between Virtual Assets and fiat - We offer the Service of purchasing Virtual Assets in fiat through various payment methods, as well as sales of Virtual Assets that are received in fiat currency into the User's linked payment account. This service may be provided by our Third Party Partners and you shall be subject to the terms of these Third Party Partners, we shall not be responsible for any incidental, direct, indirect, or consequential damages or losses that these third parties may cause to You.

5.4.7. Collateral Trading - The Virtual Assets eligible to fulfill margin and other collateral obligations for open orders and positions in each Derivative Product will be termed "Margin Collateral" within these Terms. Users must maintain collateral with Zenit in their account balance. The type and quantity of collateral will be determined based on the liquidity of the collateral asset relative to the Virtual Asset, and will be detailed on Zenit's platform. Zenit will conduct periodic risk assessments to evaluate potential risks associated with providing Products and Services to Users.

5.4.8. Margin Threshold and Liquidation - If prices move unfavorably against your secured position, your assets may face liquidation, which shall attract liquidation fees. If your margin level reaches 50%, you shall receive a margin call notification from Zenit, prompting you to either increase your collateral by depositing additional funds, or close your open positions based on your trade direction. However, if your margin level reaches 100%, this will trigger an automatic liquidation of your open position, with a subsequent profit or loss (P&L) based on the settlement. Zenit shall be authorized to liquidate your collateral assets to settle its P&L value, or

Pending Dues in full, whichever is higher, if you fail to settle the P&L within 24 hours.

5.4.9. Leverage and Margin - Zenit retains the absolute and sole authority to set the initial and maintenance margin limits, as well as the leverage constraints, applicable to every pending, unexecuted order, and any ongoing position within a Derivative Product. These standards are determined based on several factors, which include but may not be limited to the size and volume of Users' orders and positions, internal policies, market sentiment, price volatility, and the type of asset class.

5.4.10. Users should take full responsibility of ensuring they maintain an adequate Margin Collateral in their Wallet before executing an order for a Derivative Product. You may be prevented from making a trade if your Margin Collateral does not meet the minimum threshold.

5.4.11. Users hereby agree:- (i) to adhere to the minimum initial margin required by us for a specific order, (ii) any additional collateral demanded by us to support said order, and (iii) margin prerequisites for all your other Derivative Product positions. By initiating a trade order for a Derivative Product, you agree that Zenit is authorized to and will allocate a sufficient portion of the available Margin Collateral to fulfill the Margin Collateral requirements for an open order.

5.4.12. Levy of Interest Period - Within the first 24 hours of settlement or closure of an open position, Users will not be charged interest. However, following this period, Users will be charged an interest fee, which shall be calculated at a rate of 0.035% per day until such time that the User initiates settlement/closing. The same daily interest rate shall be applied to all Pending Dues until these fees are settled with Zenit.

5.4.13. Deposit/withdrawal - Virtual Assets may be deposited into your Zenit wallet from an external Wallet, and withdrawals of Virtual Asset can be made to an external wallet. However, it is expressly advised that you re-check your Wallet address before any deposits or withdrawals are made. Zenit is not liable for any incidental, direct, indirect, or consequential damages or losses of Virtual Assets due to your negligence. Further, any transactions to third-party individuals, groups and/or legal entities are not permitted from the Platform.

5.5. Our Trading Services are offered on an execution-only basis. This means that you are responsible for all trading decisions and actions with respect to the trades you enter into, including but not limited to, opening, closing, or omitting to open or close a trade.

5.6. You may be trading a complex product, for example CFDs, when you use our Trading Services. Before you trade in a complex product, we are required to assess whether the product is appropriate for you (the "Appropriateness Assessment"). We do this by obtaining from you information about your trading knowledge and experience in trading such products, and assessing that information.

5.7. If we consider that the complex product is inappropriate for you, or if you do not provide us with the required information to conduct the Appropriateness Assessment, we may not allow you to trade in such instruments or we will provide you with a warning in relation to the trading of such instruments.

5.8. The Copy Trading Services is a limited form of discretionary portfolio management. This means that, before you can engage in a copy trade, we are required to assess whether our Services are

suitable for you (the "Suitability Assessment"). This is done by obtaining from you information about your trading knowledge and experience in copy trading, your trading objectives, including your risk tolerance, and your financial situation, including whether you can financially bear losses consistent with your trading objective.

5.9. If we consider that our Copy Trading Services are not suitable for you as a result of the Suitability Assessment, in accordance with our obligations under Applicable Law and our internal policy and procedures, or if you do not provide us with the required information to conduct the Suitability Assessment, you will not be able to enter into Copy Trades on the Zenit platform.

5.10. We may update your Suitability Assessment from time to time. If there has been a change to your knowledge, experience, financial situation, or trading objectives, including your risk tolerance, you should advise us, so that we can update your Suitability Assessment.

5.11. You agree and acknowledge that the Appropriateness Assessment and/or the Suitability Assessment are performed on the basis of information and documents provided by you, and we may rely upon the information and documents provided by you and we are not responsible for any damages or losses which may arise from any inaccuracies. In addition, you agree to immediately notify us of any changes to the information and documents which you have provided, and to provide use with up to date, accurate and complete information to enable us to conduct each Appropriateness Assessment, and/or Suitability Assessment, at our reasonable request.

6. FEES

6.1. Payment of Transaction Fees - By using our Services you agree and acknowledge the Transaction Fee payable by you to Zenit for your Transactions on the Platform. Users hereby agree that Zenit has the right to revise the Transaction Fees and update them at its sole and absolute discretion. Any such revision to the Transaction Fees will apply subsequent to implementation of the effective time of the fee change.

6.2. We will also charge a Performance Fee against your Account at the point of withdrawal. The Performance Fee will be shown before you withdraw.

6.3. Other charges and fees apply, such as withdrawal fees (which can include gas fees to be determined at the point of withdrawal) and a yearly maintenance fee as per the platform.

6.4. We may, at our discretion, update the fees & charges from time to time without prior notification to Users based upon the economical factors, political factors, market fluctuations etc. Please be aware of all costs and charges that apply to you, because such costs and charges will affect the gains you generate from using our Services. All applicable fees are non-refundable and/or non-redeemable. It is always your responsibility to check the applicable fees and charges before initiating any transaction from our Platform.

7. SUSPENSION, FREEZING, BLOCK, TERMINATION AND DEACTIVATION OF YOUR ACCOUNT

7.1. We reserve the right to take various action, including but not limited to suspending, freezing, blocking, or terminating your access to any or all of our Services, in our sole discretion, without

liability to you or any third party. These actions may be taken in the following situations (without limitation):

7.1.1. If we are required to do so by an arbitration, court order, or any binding order issued by a government authority;

7.1.2. If there is a reasonable suspicion that your Account is being used in connection with a Prohibited Activity;

7.1.3. If there is a reasonable suspicion or identification of any suspicious activity or Transaction associated with your Account, particularly related to a Prohibited Activity;

7.1.4. If we reasonably identify or suspect that you are a or have potential connections to any sanctioned individuals, groups, entity, and/or countries;

7.1.5. If you are found to be violating or breaching any of these Terms, Privacy Policy, Cookie Policy, and/or any additional documents or terms of Zenit, we reserve the right to suspend, freeze, block, or terminate your access to your Account/Services.

7.2. In the event of any suspension, freezing, blocking, or termination of your Zenit Account and any of our Services, we will provide you with notice of our actions save for where a court order or other legal process prohibits us from providing you with such notice.

7.3. If You wish to deactivate your Account, you can do so by reaching out to us via email at [e-mail] Upon receiving your deactivation request, we may require you to withdraw any remaining balance in your Account within 48 (forty-eight) hours. You shall be aware that this time frame allows you to complete the necessary steps to withdraw your funds before the Account is permanently deactivated. Once you have withdrawn your Account balance as requested, we will proceed with deactivating your Account permanently. This means that you will no longer have access to the Services and features provided by us.

7.4. We reserve the right to restrict or deny withdrawals from your Account if any of the following conditions are met: (i) Your Account has been suspended or closed by us in accordance with the provided Terms; (ii) such withdrawals are prohibited by law or court order, or if we have reason to believe that the assets were obtained fraudulently; or (iii) You have not completed the necessary identity verification procedure, as indicated by Your Account.

7.5. You acknowledge and consent that the deactivation of your Account may be subject to additional charges if applicable.

7.6. If you deactivate your Account or if we suspend or terminate your Account, we reserve the right to maintain your Account registration and trading information for a period not less than 5 (five) years, in accordance with applicable laws and regulations.

8. DORMANT ACCOUNTS

8.1. If you have not carried out a Transaction for 12 months, your Account shall be considered as a “Dormant Account”. You agree and acknowledge that Zenit is entitled to charge a dormant fee of

up to 25 USD/EUR/AUD/GBP or the equivalent of 25 USD in any other currency which shall be calculated in accordance with the current exchange rate published by a recognized data provider as at the date the dormant fee is charged.

8.2. In case your Account does not reflect any transactions for a period of twelve (12) months or more and your Account has been locked or suspended then, we reserve the right to annul your Account funds.

8.3. In case of an inactive Account with a balance of 1 USD/AUD/EUR/GBP or less for 30 days we are entitled to rescind your Account funds.

8.4. If your account is closed or blocked, you must contact our Help center to recover funds from your account.

9. UNCLAIMED PROPERTY

9.1. If you have Virtual Assets held in your Zenit Account and there is no record of your use of our Services for a period of more than 5 (five) years, we may categorize these funds as "Unclaimed Property." In such cases, the funds will be placed in the custody of Zenit, and we will adhere to the applicable laws and regulations, specifically those pertaining to unclaimed property of Virtual Assets if such laws exist or are introduced in the future.

10. DEATH OF USER

10.1. In the unfortunate event of the death of a User who is a natural person, if we receive a legal document confirming the User's death or any other information that leads us to believe that the User has passed away, we will take the following action:

10.1.1. We will freeze the User's Account, which means that no transactions or activities will be permitted on the Account.

10.1.2. We may require supporting legal documentation to grant access to an appropriate successor or representative or designated fiduciary, such as:

10.1.2.1. Death Certificate: A certified copy of the User's Death Certificate, which provides official documentation of the User's passing.

10.1.2.2. Probate Document or Letter of Administration: These documents establish the legal authority of the designated fiduciary to act on behalf of the deceased User and manage their estate.

10.1.2.3. Valid Will or Similar Testamentary Document: If the User has left a valid Will or any other testamentary document specifying the designated fiduciary, we may require a copy of such a document to verify the fiduciary's authority.

10.1.3. If we determine, in our sole and absolute discretion, that there is uncertainty regarding the validity of the fiduciary designation for the diseased User’s Account, we reserve the right to

require an order from a court of competent jurisdiction to resolve any issues or disputes concerning the fiduciary designation.

11. LIQUIDATION OF USER

11.1.1. In the event of the liquidation of a Institutional Client, which is a legal entity, whether through voluntary or involuntary liquidation, bankruptcy, or liquidation by court order or authority, the Authorized person and/or the Ultimate Beneficial Owner (UBO) of such entity shall have the right to claim the Virtual Asset owned in their corporate Account.

11.1.2. To initiate the process, the Authorized Person and/or UBO of the Institutional Client will need to submit the necessary legal documents related to the liquidation of the entity. Once the documents are received and verified, the Institutional Client will be granted the right to withdraw, sell, or transfer the Virtual Asset.

12. SET - OFF

12.1. If there is any amount due to us, whether in Pending Dues or otherwise, the User expressly and irrevocably agrees that we have the right to set-off any such due amount from your Account balance.

12.2. If the funds in your Account are insufficient to cover the outstanding amount owed to Zenit, we will proceed to set-off the remaining balance by selling the necessary amount of Virtual Assets at the prevailing market price and then offset the remaining amount.

13. RISK DISCLOSURE

13.1. By availing our Services, you explicitly read, understand, acknowledge, and consent to the following risk warnings that:

13.1.1. You possess knowledge regarding the inherent risks involved in using the Platform, including but not limited to faults, defects, hacks, exploits, errors, protocol failures, delays, phishing, smurfing, malware, and double spending, connected with transactions involving fiat money, Virtual Assets, and their derivatives, and we, as the service provider, and our Third Party Partners, shall not be held responsible or liable for any such adverse risks or unfavorable outcomes that may arise from your use of our Services.

13.1.2. The assets you trade with on the Platform can fluctuate significantly and there is a material risk of economic loss when buying, selling, or holding an asset. You should therefore consider whether trading is suitable for you in light of your individual financial circumstances. The value of a trade and any returns can go down as well as up, and you may not get back the amount you deposit.

13.1.3. Third parties, including but not limited to payment providers, custodians, service providers, and Third Party Partners, may be involved in the provision of our Services. You shall be subject to the specific terms of these Third Party Partners, and we shall not be liable and/or

responsible for any direct or indirect loss, damage, compensation resulting from the provision of any service provided by a Third Party Partner.

13.1.4. It is your obligation and responsibility to keep your Zenit Account password safe, and you shall be responsible for all transactions that occur under your Account, whether you authorized them or not. Transactions in Virtual Assets may be irreversible, and losses due to fraudulent or unauthorized transactions may not be recoverable.

13.1.5. We do not guarantee that our Services will be available at any particular time or that our Services will not be subject to unplanned service outages or network congestion. In such cases you may not be able to buy, sell, store, transfer, send, or receive funds or assets. The Platform reserves the right to go offline on unplanned service outages and/or maintenance without prior notification to the Users. Nothing herein shall be considered or be deemed as a warranty by us that the Platform will be available (whether uninterrupted or available at all) during any specific times.

13.1.6. We reserve the right at any time to set, vary or cancel limits for any transaction types, functionalities, facilities, Services and products that may be carried out through the Platform, whether in monetary or numerical terms or otherwise, and to vary their frequencies and availability period.

13.1.7. We may limit, cancel, suspend or make changes to the Platform in whole or in part at any time without prior notice or liability to the Users. Notwithstanding any representation to the contrary, we shall at any time, in our discretion and without prior notice, be entitled to temporarily suspend the operations of the Platform for updating, maintenance and upgrading purposes or any other purposes whatsoever that we deem fit, and in such event, we shall not be liable to anyone.

13.1.8. The aforementioned risks do not explain all of the risks, or how such risks relate to your personal circumstances. It is very important that you fully understand the risks involved with regard to your personal circumstances, before deciding to use our Services. Refer to our Risk Disclosure for further information.

13.2. In accordance with the Terms provided, we shall assume that you have read and understood the Risk Disclosure available on our Platform. The Risk Disclosure is designed to provide information about the risks associated with the services offered by Zenit. Each Service provided by Zenit carries its own distinct risks, and you shall be aware of and understand these risks before using our Services. The Risk Disclosure document aims to outline these risks to help you make informed decisions. However, it's essential to note that the Risk Disclosure available on our Platform may not cover every risk that you may encounter while using Virtual Assets. Further, it may not address how these risks specifically relate to Your personal circumstances. Therefore, it is advisable to consider Your individual situation, risk tolerance, and seek independent advice if necessary.

13.3. By accessing or using our Platform, you are voluntarily choosing to engage in sophisticated and

risky asset Transactions. You are further acknowledging that you are aware of the inherent risks associated with using cryptographic and blockchain-based systems including, but not limited to, risks of financial loss, technology glitches, and hacking. Zenit strives to provide state-of-the-art systems and security measures to safeguard User Virtual Assets. However, you shall note that certain issues and risks are unavoidable in any technological system. In the event that you encounter issues or problems while using our Platform, such as technical difficulties with depositing or trading Virtual Assets, it may take a significant amount of time to resolve these issues, ranging from days to weeks or even months. Furthermore, there may be instances where certain issues cannot be resolved at all. You shall be aware of these risks and exercise caution when using our Platform. This includes being prepared for potential delays or difficulties that may arise and understanding that the resolution of such issues may not always be immediate or guaranteed.

13.4. We are committed to addressing and resolving any issues that may arise to the best of our ability. Our Platform strives to provide a reliable and secure environment for Users to engage in asset transactions. However, it is essential for Users to be mindful of the inherent risks associated with asset transactions and to exercise diligence and risk management practices. While Zenit takes measures to mitigate risks, it is ultimately the responsibility of Users to make informed decisions and manage their own risk exposure.

13.5. To ensure a safer and more secure experience on our Platform, you are encouraged to:

13.5.1. Educate yourselves to gain a comprehensive understanding of the Virtual Assets you are trading, the market dynamics, and the associated risks.

13.5.2. Conduct thorough research and stay informed about the latest developments, news, and market trends that may impact their trading decisions.

13.5.3. Implement risk management strategies to set appropriate risk thresholds, diversify their portfolio, and use tools such as stop-loss orders to limit potential losses.

13.5.4. Keep personal information secure and safeguard login credentials, enable two-factor authentication, and be cautious of phishing attempts or suspicious communications.

13.5.5. Adhere to these Terms and guidelines, security protocols, and recommended practices provided by us.

13.6. In any circumstances if we identify and/or suspects that you have engaged in crypto Market Manipulation including Pump and Dumps scheme, Front-Running, Wash trading, Spoofing and Layering, Stop hunting, Churning, Quote stuffing, False trading, Insider dealing, Price rigging, any deceptive activity, we reserve the sole discretion to freeze, suspend and/terminate your Transactions/Account in our Platform.

14. DISCLAIMER OF WARRANTIES

14.1. To the maximum extent permitted under applicable law, Services provided by or on behalf of Zenit are offered on an “as is'' and “as available” basis, without any representation or warranty, whether we expressly, impliedly, or statutorily disclaim them, and you waive, any and all other warranties of any kind, whether express or implied, including, without limitation, warranties of merchantability, fitness for a particular purpose, title, or non-infringement or warranties arising from course of

performance, course of dealing, or usage in trade. Without limiting the foregoing, we do not represent or warrant that our Platform or Services are accurate, complete, reliable, current, error-free, or free of viruses or other harmful components. Further, we do not guarantee that any order will be executed, accepted, recorded, or remain open. Except for the express statements, agreements, and rules set forth in these Terms you hereby acknowledge that information you store or transfer through the Services may become irretrievably lost, corrupted, or temporarily unavailable due to a variety of causes, including software failures, protocol changes by third-party providers, internet outages, force majeure events, or other disasters, including third party distributed denial of service (DDoS) attacks, scheduled or unscheduled maintenance, or other causes either within or outside our control. You are solely responsible for backing up and maintaining duplicate copies of any information you store or transfer through our Services.

15. NON-SOLICITATION; NO FINANCIAL ADVICE

15.1. You agree and understand that all transactions and projects you participate in through Third Party Partner Platforms are considered unsolicited, which means that you have not received any inducement or advice from us and that we do not conduct any suitability or financial means assessments.

15.2. All information provided on the Platform is for informational purposes only and should not be construed as financial advice. You should not take, or refrain from taking, any action based on any information contained on the Platform. We do not make any recommendations to you or opine on the merits of any transaction or opportunity. You alone are responsible for determining whether any project or related transaction is appropriate for you based on your personal objectives, financial circumstances, and risk tolerance.

16. LIMITATION OF LIABILITY

16.1. In no event shall Zenit, its affiliates and service providers or any of the respective officers, shareholders, members, directors, officers, employees, attorneys, agents, representatives, suppliers, joint ventures or contractors, be liable for any special, incidental, indirect, intangible, punitive, consequential damages or any lost profits, diminution in value, any loss, damage, breach of data arising out of Services, any performance or non-performance of Services or other product provided by or on behalf of Zenit and its affiliates, whether under tort, contract, statute, strict liability, negligence or otherwise arising out of or in connection with authorized or unauthorized use of our Platform or Services or contract even if an authorized representative of Zenit has been advised of or knew or should have known of the possibility of such damages, and notwithstanding the failure of any agreed or other remedy or compensation of its essential purpose, except to the extent of a final judicial determination that such damages were result of our gross negligence, fraud, willful misconduct or intentional violation of law. Some jurisdictions do not allow the exclusion or limitation of incidental or consequential damages, so the above limitation may not apply in such cases.

17. INDEMNIFICATION

17.1. You agree and acknowledge that you will indemnify and hold Zenit, its affiliates, service providers, directors, agents, respective officers, employees, joint venturers, representatives, contractors, and licensors harmless from any and all claims, demands, losses, proceedings, suits, or damages, costs or expenses, including attorney’s fees, and any fines, fees, or penalties imposed by any regulatory authority arising out of or related to any violation or breach of the Terms and other relevant documents or any applicable law, regulation, or rights of any third party. In such circumstances, we reserve the right, in our sole discretion, to control any action or proceeding in the manner we wish to settle it.

18. FORCE MAJEURE

18.1. We shall not be held liable if we fail to comply with these Terms due to circumstances beyond our reasonable control. In no event shall Zenit be responsible for inaccuracies, errors, delays, omissions, service disruptions, or interruptions in the Services, whether in transmission or delivery of information as required by these Terms. Such circumstances include but are not limited to, forces beyond the reasonable control of Zenit, such as governmental actions, regulatory developments, acts of terrorism, war, fires, disruptions in telecommunications or internet services, network provider issues, software malfunctions, network-wide compromises, hacking, strikes, labor disputes, accidents, civil or military disturbances, or any catastrophic events.

19. CLASS ACTION WAIVER

19.1. You and Zenit agree that, to the extent permissible by law, all claims must be brought in a party’s individual capacity, and not on a class, representative, or collective basis, and the parties hereby agree to waive all rights to have any dispute brought, heard, administered, resolved, or arbitrated on a class, collective, or representative basis. Disputes involving more than one User cannot be arbitrated or consolidated with those of any other User. Combining or consolidating individual Arbitrations into a single Arbitration is not permitted without the consent of all parties. The purpose of this provision is to establish that disputes will be resolved individually rather than through collective or class actions.

20. TRANSFER OF BUSINESS

20.1. In the event of a transfer of the whole or part of the business of Zenit to any third party (“Business Transferee”), Users hereby consent that their Account, assets, liabilities and Personal Data may be duly transferred to the Business Transferee for the continuation of the User’s access to our Services.

21. PRIVACY POLICY

21.1. Protection of your privacy and your Personal Data are of utmost importance to us. We are committed to handling your Personal Data responsibly and in accordance with applicable data protection laws. To understand how we collect, use, store, and disclose your personal information, as well as your rights and options regarding your personal information, please review our Privacy and Cookies Policy.

22. MODIFICATIONS

22.1. Zenit reserves the right, at our sole discretion, to modify, amend, supplement, or replace the Terms and the Policies at any time indicating the date on which the latest changes were published at the top of this page.

22.2. Our Platform Policies and Terms may be revised or updated periodically to meet the necessary requirements and standards. Zenit encourages you to regularly visit our Platform to stay informed about any changes to these Policies and the Terms. Your continued access to the Platform means that you agree to the updated content and to abide by the updated Terms. The most updated version of this Policy is available at https://www.zenit.world.

23. GOVERNING LAW

23.1. The laws of the Union of Comoros shall apply to these Terms. Any dispute arising out of or in connection with these Terms, including any question regarding their existence, validity, or termination, shall be referred to Zenit’s Customer Support team in the first instance, to determine whether the dispute can be resolved informally. Failing resolution, the matter shall be referred to and finally resolved by the Courts of the Comoros Union. The proceedings shall be conducted in the English language.

24. CONTACT US

24.1. If you have any complaints or other inquiries, please visit https://www.zenit.world and complete our contact form, or email us directly at [e-mail].

Third Party Partner List:

Services	Name of the Service Provider
Customer KYC	Sumsub
Digital Asset Custody	Fireblocks
Transaction Monitoring	Chainalysis