Pi42 - Trading Policy

Pi42.com Platform (as defined hereafter) is operated and managed by LIGHTNINGNODES TECHNOLOGIES PRIVATE LIMITED (CIN: U62099GJ2023PTC143842), having its registered office at 1328, Gala Empire, Drive-in-Road, Memnagar, Thaltej Road, Ahmedabad-380054, Gujarat (hereinafter referred to as “Company” or “Us” or “We” or “Our”, which term shall mean and include our affiliates, group entities, related parties and service providers).

This Trading Policy is an integral part of the User Terms and Conditions. By signing up, accessing, using or continuing to browse through Pi42.com Platform or using our Services, whether as a guest or registered user, you agree that you have read, understood, and accepted each of the terms contained herein and agree to be bound by the same.

If you have objections to this Trading Policy, or any part thereof, and/or if you do not agree to be bound by these terms, or any part thereof, please do not access Pi42.com Platform and do not use our Services in any manner.

This version of the Trading Policy shall replace and supersede any previous versions of these terms that may have been accepted through, or otherwise made available on, the Pi42.com Platform.

 

1 - INTRODUCTION

 

1 a) This Trading Policy governs the access to and use of Pi42.com Platform. This Trading Policy must be read in conjunction with the User Terms and Conditions.

 

1 b) We reserve the right to change, amend, remove, modify, suspend or discontinue this Trading Policy (in whole or in part). You shall regularly and periodically check this Trading Policy including before you make any transaction on Pi42.com Platform. We shall have no liability or responsibility whatsoever due to any such changes, additions, removals or modifications.


2 - DEFINITIONS

 

2 a) Unless the context requires otherwise, following terms shall have meanings ascribed to them as below.

 

2 b) AML Regulations means India’s Prevention of Money Laundering Act, 2002 and the rules, regulations, circulars and guidelines framed thereunder.

2 c) VDA Wallet means an online VDA wallet accessible through Pi42.com Platform and owned and operated by a User for storage of their VDAs.  

2 d) Cryptos or VDA means any “virtual digital asset” as defined under the Indian Income Tax Act, 1961, as amended or superseded from time to time.

2 e) Account means the registered account of the User on Pi42.com Platform.

 

2 f) Pi42.com means our electronic trading platform system which includes the aggregate of its computer devices, software, database, communication system and all programs and technical facilities associated therewith to enable the User to access Services, obtain Wallet information, receive notices from us and keep record of transactions, settlement obligations.

2 g) Pi42.com Platform collectively means and includes Pi42.com (as defined above), Pi42.com Android app, Pi42.com iOS app, Pi42.com web app, Pi42.com website “https://pi42.com/”, and other web assets on Pi42.com domain, together with the Pi42.com developer portal, public APIs and secure authentication for Users (all either existing or available in the future).

 

2 h) Funds or Holdings refers to both VDA and/or INR, as the case maybe, held in the User’s VDA Wallet or INR Wallet.

 

2 i) INR means Indian Rupees.

 

2 j) INR Wallet means a virtually denoted ledger accessible through Pi42.com Platform and operated by a User, which ledger denotes the Users' INR Holdings and acts as a closed loop system that can only be used to trade with the Company.

2 k) KYC means know your customer requirements as determined by us or under the AML Regulations.

2 l) Linked Bank Account refers to any Indian bank account of the User (except a joint bank account) which is authenticated or verified as per KYC requirements and from/to which the User can make top-ups/withdrawals from INR Wallet. Linked Bank Account shall not be a joint account.

 

2 m) Services means all content, functionality and services made available to Users through Pi42.com Platform including but not limited to: (a) exchanging USD Tether (“USDT”), a VDA, or other VDAs for INR, after a User first credits their Account balance with USDT / other VDAs by means of a VDA Wallet incoming transfer from their own external VDA wallet; (b) trading with the User in VDA/crypto-INR perpetual futures or INR-Options pairs (with an option for us to seek delivery in accordance with the User Terms and Conditions and this Trading Policy), for a Transaction Fee; and (c) any other products, services or offerings as may be introduced from time to time. In respect of transactions, the Users accessing Pi42.com Platform will be contracting with the Company, which will be the counterparty to all transactions except with regard to VDA incoming transfers into a User's VDA Wallet (in which regard Pi42.com Platform merely facilitates the transaction as an intermediary).

2 n) User or You or Your means visitors to Pi42.com Platform or persons otherwise using Pi42.com Platform or availing of the Services, directly or indirectly, including by transacting on Pi42.com Platform.

2 o) Wallet(s) refers to the “VDA Wallet” and/or “INR Wallet” provided to the User, as the case maybe.

2 p) Terms not defined in this document but defined under the User Terms and Conditions shall have the meaning ascribed to them therein.

3 - YOUR WALLETS

3 a) Upon creation/activation of your Account and till such time your Account is active, you will be provided access to an INR Wallet and a VDA Wallet address to enable you to trade VDA derivatives (including perpetual futures contracts or crypto-options contracts) or store VDA supported on Pi42.com Platform. You are required to maintain a minimum balance of Funds before you initiate any sale/purchase order. We reserve the right to refuse to execute/effect any order and/or transaction initiated by you, if they are in contravention of the KYC-AML Policy or non-compliant with directions of appropriate enforcement authorities.

 

3 b) Terms of INR Wallet:

 

i) As part of your Account, an INR Wallet facility is provided to you for storage of your INR Holdings. You can only transfer INR denominated funds (and not any other currency whatsoever) from your Linked Bank Account to your INR Wallet. You are the owner of INR balances in your INR Wallet. INR Wallet is a non-interest-bearing account and you will not receive any interest on Funds held therein. Any INR funds paid by you are an advance and must be utilised within 300 days or withdrawn by you into your Linked Bank Account failing which we will attempt to return the funds to you. In case we are unable to return the Funds with reasonable efforts, we have no option but to forfeit the amount with intimation to you.

ii) When you make an INR transfer from your Linked Bank Account to INR Wallet, your Funds shall reflect in your INR Wallet subject to any delays in the relevant banking channels, payment gateway transfers or similar issues. If your top-up/transfer is invalidated for any reason, we shall not be liable to you to any extent and you have no recourse against us.

 

iii) We shall monitor transfers made into your INR Wallet for high-risk & fraudulent transactions as per our KYC-AML Policy available here. If your transfers are classified as high-risk transactions or are suspected of fraud, we will place a hold on the transfer and may ask you for more information on you as may be required. We will conduct a review and will accordingly either clear or cancel the transfer. If the transfer is cleared, we will notify you and update your INR Wallet. Otherwise, we will cancel the transfer and the funds shall be returned to your Linked Bank Account or forfeited. We will notify you by email and/or in the account history tab of your INR Wallet if the top-ups are cancelled. We reserve the right to delay withdrawals while screening for risk, request that you provide additional information to verify your identity, and limit the amount you can withdraw until the information is verified.

As part of your Account, a VDA Wallet address facility is provided to you for transfer of your VDA. We allow Users to have only one INR Wallet. For VDA deposits, the VDA gets converted to INR after a compliance check. When the amount gets credited, only then the Users can start the trading on the Pi42 Platform.

We will only accept the deposits if the User has deposited from his own VDA Wallet. A VDA deposit done by the User from a third-party wallet will not be permitted in the Pi42 Platform.

3 c) Transfer or withdrawal requests: Wallet-to-wallet deposits or transfers between Users or different Accounts are not permitted. You may withdraw surplus Funds from your INR Wallet at any time by placing a withdrawal request. We will endeavour to process each withdrawal request as reasonably as practicable and the same shall be subject to the User Terms and Conditions, the AML Policy, this Trading Policy, and such restrictions and limits as may be notified on Pi42.com Platform from time to time.

 

3 d) You agree and understand that your Wallets are closed loop instruments which are not regulated by the Reserve Bank of India. You cannot use funds in your INR Wallet for settlement of payment obligations for purchase of goods/ services / VDAs from third parties other than us. You can use such Funds only to trade in VDAs and/or VDA derivatives (including perpetual futures and options) with the Company through Pi42.com Platform. You agree and understand that we do not operate a payment system.

4 - CUSTODY AND TITLE OF DIGITAL ASSETS

 

4 a) Appointment: You agree to hereby appoint us to act as the custodian of the VDA held by you in the Wallet, to be held in trust by us for your benefit in accordance with this Trading Policy, and we accept such appointment and the obligations, duties, and responsibilities set out in this Trading Policy. You agree, understand and authorise us to enter into agreements or arrangements with third party service providers for custodial services and ledger services as may be required for maintenance and operation of the Wallets from time to time.

 

4 b) Title: The VDA held in trust will be fully-paid assets legally and beneficially owned by you.

5 - GENERAL TERMS FOR PLACING ORDERS

 

5 a) Authorization: When you submit an order through Pi42.com Platform, you authorise us to execute a transaction as per your instructions in accordance with such order and charge you a fee for our Services.

 

5 b) Errors: We provide you with the tools to verify your order before confirming it so that you have the opportunity to catch a mistyped order. We will not be responsible for losses/damages/costs induced by mistyped or otherwise wrongly placed orders. Notwithstanding the foregoing, in the event we determine, at our sole discretion, that as a result of a technical issue an executed order did not reflect the fair market value for the applicable VDA or VDA derivatives, we may cancel or correct such order.

 

5 c) Cancellation Policy: Orders initiated by you on Pi42.com Platform are final, irreversible, non-refundable and non-cancellable to the extent such orders are executed whether fully or partially. Limit Orders can be cancelled, amended until the point of execution. Once a transaction is initiated by you on Pi42.com Platform, the said transaction is absolute and unconditional. You cannot seek or claim or demand refund or reversal for any reason whatsoever nor can it be cancelled, modified or reversed by us/ anyone else upon your/ third-party request. We reserve the right to cancel/negate any orders if such orders are placed during scheduled or unscheduled downtime or violates any terms. We reserve the right at our sole discretion whether or not to accept any order or instruction and we are not responsible for any losses incurred as a result of our decision to cancel or refuse an order placed by you.

 

5 d) No Refund: You will not be entitled to refund or cancellation in following circumstances:

i) you fail to provide us with any information or documents when requested in accordance with the User Terms and Conditions, the AML Policy or this Trading Policy,

ii) we suspect that the User has, or is, engaged in, or has in any way been involved in any fraudulent or illegal activity, any money laundering, any terrorist financing, or breach of any relevant laws in any jurisdiction.

 

5 e) Execution, Volatility: You agree and understand that our algorithm provides the price for a specific quantity of VDA or VDA derivatives based on various factors like high volatile nature and market fluctuations, exchange fees, changes in prices in the order book, fractions of VDA or VDA derivatives available for transactions and you are aware that specific price shown on Pi42.com Platform which is based on algorithms may change during the actual execution of trade on Pi42.com Platform. You can view the details of the actual execution of the transaction under your Account. You consent to us absorbing any negative change and/ or retaining or refunding (at its sole discretion) to you, any positive change of price variation in executing the orders.

 

5 f) Suspicious Activity: We may decline to process any transaction from your Wallet or any orders or any other service offered by us or any part thereof without any notice and may limit or suspend your use of one or more Services at any time, in our sole discretion. We may delay transactions if we believe the transaction (a) is suspicious, (b) may involve fraud or misconduct, (c) violates applicable laws or third party rights, (d) violates the terms of this Trading Policy, the AML Policy and/ or the User Terms and Conditions, or (e) is otherwise required to be delayed, in our sole and absolute discretion. You understand that we shall have no liability or responsibility for such termination/suspension or any losses arising therefrom. We reserve the right to block any user from making bank transfers if there are reasonable grounds to believe that the same (a) is not in accordance with the terms of this Trading Policy, the AML Policy, the User Terms and Conditions and/or applicable law and/or (b) it is suspicious that the user is misusing or fraudulently transacting. We may report such suspicious activities to the concerned statutory/law enforcement agencies. Any withdrawal found to be suspicious will be held back and reversed. The Wallet facility will also be suspended for operations and no transactions will be possible pending an investigation.

6 – TERMS FOR TRADING IN CRYPTO OPTIONS

 

6 a) Definitions:

Unless the context requires otherwise, following terms shall have meanings ascribed to them as below.

  1. Call Contract means a contract entitling the Option Buyer, upon Exercise, to purchase the Digital Asset Quantum from the Option Seller at the applicable Strike Price and to receive from the Option Seller, in lieu of the Digital Asset Quantum, the Settlement Amount.

  1. Commencement means the time at which the Option Contract is entered into on the Pi42.com Platform.

  1. Digital Asset Quantum means the quantum of the Underlying Asset that is to be bought or sold pursuant to an Option Contract.

  1. Eligible Digital Asset means any VDA that the Company has confirmed it will accept for the purposes of satisfying Margin Requirements with respect to Option Contracts.

  1. Exercise means the exercise of the rights of the Option Buyer granted pursuant to an Option Contract, as applicable. Exercise will be automatic on Expiry of the Option if the Option is In-the-Money.

  1. Exercise Period means the period from Commencement to Expiry.

  1. Expiry means the expiration time chosen or specified on the Pi42.com Platform when entering into the relevant Option Contract.

  1. In-the-Money means the Settlement Amount with respect to an Option Contract is a positive amount in favor of the Option Buyer at the time of Expiry of the Option Contract.

  1. Initial Margin means, in relation to an Option Seller, the minimum amount of Margin that the Company may, from time to time and in its sole discretion, determine is required to be deposited in the Option Seller’s Account in order to write/issue Option Contracts.

  1. Maintenance Margin means, in relation to the Qualifying User the amount of Margin that the Company may, from time to time and in its sole discretion, determine to be required to maintain a short position in relation to Option Contracts issued by the Qualifying User.

  1. Margin, in respect of a Qualifying User, means any Eligible Digital Assets that are deposited with or held by or on behalf of the Company in the Account of such a Qualifying User as security or credit support for the obligations of the Qualifying User under the relevant Option Contracts issued by the Qualifying User.

  1. Margin Balance means, with respect to the Account of a Qualifying User the sum, from time to time (as determined by the Company in its sole discretion) of: (a) Margin held in such Account; and (b) any Unrealised P/L connected to such Account. Information as to the Margin Balance from time to time is made available through the Pi42.com Platform.

  1. Margin Call means, with respect to a Qualifying User, the request issued by the Company to top up any shortfall of Margin in the Qualifying User’s Account in order to satisfy Margin Requirements from time to time.

  1. Margin Requirements means the aggregate of Initial Margin and/or Maintenance Margin required to be satisfied by a Qualifying User in order to sell/issue and/or maintain short positions with respect to Option Contracts, as specified by the Company from time to time.

  1. Options means options contracts based on underlying VDAs available for purchase or sale on the Pi42.com Platform that are quoted in USDT and settled in INR and are automatically Exercised on Expiry if the Option is In-the-Money (and may not be Exercised prior to Expiry).

  1. Option Buyer means the party that pays the Premium to the Option Seller and is entitled to receive from the Option Seller, upon Exercise, the Settlement Amount.

  1. Option Contract means a Call Contract or a Put Contract in respect of any Option.

  1. Option Seller means the party that grants to the Option Buyer, upon Exercise, the right to receive the Settlement Amount.

  1. Option Specifications means the contract specifications with respect to each type of Option Contract available through the Pi42.com Platform, as accessible here.

  1. Order means any offer to enter into an Option Contract, or any instruction, request, application or order in relation to an Option Contract in whatever form and howsoever sent, given or transmitted by you or on your behalf to the Company, or which the Company reasonably believes to have been sent, given or transmitted by you or on your behalf, including any instruction, request or order to revoke, ignore or vary any previous offer, instruction, request application or order.

  1. Premium means an amount in INR paid by the Option Buyer to the Option Seller to enter into an Option Contract, as specified on the Pi42.com Platform.

  1. Put Contract means a contract entitling the Option Buyer, upon Exercise, to sell the Digital Asset Quantum to the Option Seller at the applicable Strike Price and to receive from the Option Seller, in lieu of the Digital Asset Quantum, the Settlement Amount.

  1. Qualifying Users means Users whom the Company has agreed shall be permitted to provide liquidity in Options and to issue/write (and take short positions in respect of) Option Contracts, subject to the satisfaction of applicable Margin Requirements as detailed in Clause 6(f) of this Trading Policy.

  1. Settlement Amount means the greater of (a) zero, and (b) the amount calculated on a formula basis as follows: (A) in the case of a Call Contract, the excess of the Settlement Price over the Strike Price, multiplied by the Digital Asset Quantum, and (B) in the case of a Put Contract, the excess of the Strike Price over the Settlement Price, multiplied by the Digital Asset Quantum.

  1. Settlement Price is the arithmetic mean of the Spot Index Price in respect of the Underlying Asset during the 30 minutes preceding the Exercise of the relevant Option Contract, as determined by us.

  1. Strike Price is the predetermined price, agreed upon when entering into an Option Contract, at which the relevant Option Contract can be Exercised, as specified on the Pi42.com Platform.

  1. Time to Expiry means the period of time until the Expiry of the Option.

  1. Underlying Asset means the VDA that is the subject of the Option Contract.

  1. Unrealized P/L means the profits that have not yet been realized on your open Option Contracts minus the losses that have not yet been realized on your open Option Contracts. Information as to your Unrealized P/L from time to time is made available on the Pi42.com Platform.

6 b) Entry into Option Contracts:

To enter into an Option Contract or close out an existing open position with respect to an Option Contract entered into through the Pi42.com Platform, you may place a relevant Order with the Company through the functionality available on the Pi42.com Platform. The Company is not obliged to accept, and does not guarantee the execution of, any Order.

Option Contracts may only be issued by Qualifying Users who have been approved on Pi42.com Platform. The issuance of Option Contracts and the entry into a short position with respect to an Option will be subject to the satisfaction of Margin Requirements as set out in Clause 6(f) below.

When placing an Order to enter into an Option Contract through the Pi42.com Platform, you will need to select an Expiry. Options can only be Exercised at Expiry and will be automatically Exercised once Expiry is reached provided that the Option is In-the-Money. You may choose a daily, weekly, monthly, or quarterly Expiry. The different Expiries available are detailed on the Pi42.com Platform. Once an Expiry is chosen for a particular Option Contract, this cannot be changed.

On entering into an Option Contract as an Option Buyer, you will be required to pay the applicable Premium to the Option Seller, which will be automatically deducted from your Account. It is your responsibility to ensure that you maintain sufficient Client Funds in INR to cover any Premium due with respect to Option Contracts. If you do not have sufficient Client Funds to satisfy any Premium due, you will not be permitted to enter into any Option Contract.

If you place an Order to close out an existing open position with respect to an Option Contract and this Order is matched, the amount you will receive will reflect the current market price of your position (as determined by us). Once you have closed out a position in an Option Contract, you will no longer have any rights or obligations with respect to such an Option Contract (and you will not be entitled to receive, or required to pay, as applicable, any Settlement Amount on Expiry).

Where you are the Option Buyer, we act as the Option Seller, and vice versa.

6 c) Exercise of Options:

Options entered into through the Pi42.com Platform may only be Exercised at Expiry. If at Expiry an Option is In-the-Money, the Option shall be deemed to be automatically Exercised immediately upon Expiry. For the avoidance of doubt, if an Option is not In-the-Money at Expiry, the Option will lapse and will not be Exercised.

6 d) Settlement of Options:

At Expiry of an Option, the Settlement Amount will be determined by the Company. If the Settlement Amount is greater than zero, the Option will be automatically Exercised and the Settlement Amount will be automatically deducted from the Option Seller’s Account and credited to the Option Buyer’s Account. The Settlement Amount will be paid in INR (with an option for the Company to seek delivery in accordance with the User Terms and Conditions and this Trading Policy).

The net profit for an Option Buyer with respect to each Option Contract will represent the Settlement Amount for the Option Contract, minus the Premium paid and any applicable fees. As an Option Buyer, the maximum loss with respect to an Option Contract will be limited to the amount of Premium paid, plus any fees. In contrast, as an Option Seller, the maximum profit for an Option Contract will be the Premium received and the maximum loss will be the Settlement Amount (which reflects the difference between the Strike Price and the Settlement Price), which is unlimited.

Information as to Option Contracts entered into will be made available through the Pi42.com Platform (including, inter alia, information on the applicable symbol, underlying VDA, Premium, Strike Price, direction — i.e. Call Contract or Put Contract — Transaction Fee Rate, and, if relevant, information on the Initial Margin and Maintenance Margin requirements). The Company will not actively notify you of any upcoming Expiry. You acknowledge and agree that it is your sole responsibility to monitor the Time to Expiry.

By entering into (or closing out positions in respect of) Option Contracts through the Pi42.com Platform, you authorize the Company to automatically: (i) deduct from your Account (Client Funds) any amounts owed by you with respect to such Option Contracts, and/or (ii) credit to your Account (Client Funds) any amount owed to you with respect to such Option Contracts.

The nature of Options offered on the Pi42.com Platform are valid contracts involving genuine commercial transactions of sale and purchase, since the Company has the right, but not the obligation, to compel delivery of the Underlying Assets in accordance with its terms and policies. Where you are the Option Buyer in such cases, you will not be allowed to refuse taking delivery and where you are the Option Seller, you shall not default in making delivery.

6 e) Fees:

The Company charges Transaction Fees, and also fees for the Exercise of Options (“Exercise Fees”). 

Transaction Fees are payable by both the Option Buyer and Option Seller in respect of each Option Contract entered into through the Pi42.com Platform. Transaction Fees are payable upon entry into and closing out of an Option Contract and are determined by reference to the Spot Index Price at the time of entry into/closing out of the Option Contract and the applicable “Transaction Fee Rate” as published on the Pi42.com Platform from time to time, which may vary depending on whether you are the maker or taker of an Order. 

Exercise Fees are payable upon Exercise of an Option by both the Option Buyer and the Option Seller. The Exercise Fee is determined by reference to the applicable Settlement Price and the applicable “Exercise Fee Rate.”

Transaction Fees and Exercise Fees are automatically deducted from the Account (Client Funds) of the Option Buyer and the Option Seller and are payable in INR. The Company reserves the right to change applicable Transaction Fees and/or Exercise Fees (including the applicable Transaction Fee Rate and/or Exercise Fee Rate) from time to time, at its sole discretion and without prior notice. Further information on the calculation of Transaction Fees and Exercise Fees (including the applicable Transaction Fee Rates and Exercise Fee Rate) is set out on the Pi42.com Platform and can be accessed here.

6 f) Terms applicable to Qualifying Users authorized to write/issue Options:

The Company currently only permits Qualifying Users to write/issue Option Contracts and open and maintain short positions, subject to the terms and conditions as set out in the User Terms and Conditions, this Trading Policy and any additional documentation as the Company may require from time to time. In order to issue/write an Option Contract and/or open a short position in an Option through the Pi42.com Platform, a Qualifying User must first deposit the required amount of Initial Margin to their Account. In order to maintain a short position in an Option Contract, an Option Seller must meet applicable Maintenance Margin requirements. Further information on how Initial Margin and Maintenance Margin requirements are determined can be accessed here.

A Qualifying User must maintain sufficient Initial Margin and Maintenance Margin at all times. If the value of an Option Contract moves against a Qualifying User, the Company may issue a Margin Call to request that the Qualifying User deposit additional VDA to their Account in order to ensure that the Margin Balance of the Account does not fall below the Maintenance Margin requirements. The Company is not required to make a Margin Call. However, if a Margin Call is made, it will be made via the Platform, by email or other electronic means. It is the sole responsibility of a Qualifying User to monitor the applicable Margin Requirements and the Margin Balance of their Account from time to time and to ensure that the Margin Balance of the Account is at all times equal to or greater than the required Maintenance Margin, so as to avoid triggering a Default (as described further below).

The Unrealized P/L of a Qualifying User who has issued or otherwise taken a short position in respect of an Option Contract is relevant for the purpose of determining Margin Requirements and is calculated by reference to the real-time value of the Option Contract (the “Mark Price”). The Mark Price is determined by the Company through reference to the volume-weighted average of the spot prices of the Underlying Asset on the major spot market exchanges that the Company has determined shall constitute the “Price Index” (the “Spot Index Price”), and other parameters as determined by the Company. Further information in relation to the “Price Index” and the protective measures that may be implemented by the Company to avoid poor market performance and inaccurate pricing data can be found here.

The value of any Margin shall be as determined by the Company in its sole and absolute discretion. The Company may, in its sole and absolute discretion, with or without notice to a Qualifying User, vary the Margin Requirements at any time and by any amount, and may also stipulate that such Margin Requirements apply to existing Option Contracts, as well as new Option Contracts affected by such change. A higher Initial Margin may be payable in certain circumstances and the Maintenance Margin may increase in the event of adverse market movements. The Company may, in certain market conditions, effect an immediate change in Margin Requirements and/or require additional Margin to be deposited immediately or within a specified period of time, which may be less than 24 hours. No previous Margin Requirements shall set a precedent or bind the Company.

If at any time: (i) a Qualifying User fails to maintain sufficient Margin in their Account so that the Margin Balance of the Account is at all times equal to or greater than the required Maintenance Margin, and/or (ii) a Qualifying User fails to make payment of any amount under an Option Contract when due, this shall constitute a “Default” for the purposes of this Trading Policy. Accordingly, without prejudice to any other rights or remedies granted to the Company in the User Terms and Conditions or this Trading Policy, and regardless of whether or not a Margin Call has been issued, the Company may (but is not obliged to), as a counterparty to the trade with the Qualifying User, immediately or any time thereafter, exercise any of its rights as set out in below (under Default and Termination) of this Trading Policy and Conditions as a consequence of such Default.

Default and Termination: For the avoidance of doubt, rights of the Company in the event of Default include (but are not limited to) liquidating, accelerating, hedging, and/or closing out any outstanding Option Contract entered into by the Qualifying User (whether in a capacity as Option Seller or Option Buyer), including any Option Contract that has yet to be settled on the date on which the Company terminates such an Option Contract, in accordance with the User Terms and Conditions and/or selling or otherwise transferring any VDA or other property the Company may hold for the Qualifying User and applying the proceeds to the discharge of the Qualifying Users obligations owed under or in connection with an Option Contract.

For the avoidance of doubt, the provisions of this Clause 6(f) shall only apply to Qualifying Users who write/issue Option Contracts and take short positions with respect to Options.

6 g) Risks of Transacting in Options

Before entering into an Option Contract, you must ensure that you have sufficient Client Funds in INR to satisfy any applicable Premium due. The Premium is a fixed value which will be deducted from your Account when you enter into an Option Contract as an Option Buyer. All Option Contracts will be purchased and Exercised on the basis of market prices, which may fluctuate from time to time. As such, there is no guarantee that prices displayed on the Pi42.com Platform will be current and will be the exact prices at which Option Contracts will be purchased and/or Exercised. Returns on Options trading will depend on market movements.

The net profit for an Option Buyer with respect to each Option Contract will represent the Settlement Amount for that Option minus the Premium and applicable fees. As an Options Buyer, the maximum loss will be limited to the amount of Premium paid and applicable fees.

As an Option Seller, your maximum profit with respect to the sale of an Option Contract will be the Premium paid by the Option Buyer (less any applicable fees). In terms of the maximum loss of an Option Seller, this will be the difference between the Premium and the Settlement Amount (which represents the difference between the Settlement Price and the Strike Price of the Option).

If you are a Qualifying User who is permitted to write/issue Option Contracts and take short positions in respect of Options, you will be required to meet Margin Requirements and may be subject to Margin Calls from time to time which will require you to top up additional Margin in your Account in order to avoid triggering a Default. As VDA and VDA derivatives markets are open 24 hours a day, 7 days a week, Margin Calls may occur at any time, including outside of normal business hours. You further agree and acknowledge that the prices of VDAs or VDA derivatives are volatile and thus may decline speedily. If, as a Qualifying User, the Margin Balance of your Account falls below the required Margin Requirements and you fail to top up the Margin held in your Account then (subject to any applicable grace period agreed in writing with the Company), you may be put into Default. This means that you may lose all of your Margin credited to your Account and you may owe substantially more than you initially invested with respect to Options trading. 

The Company reserves the right to delist any Option available through the Pi42.com Platform and/or to discontinue providing any of the services referred to hereunder, in each case at any time in its sole and absolute discretion.

7. TERMS FOR TRADING IN PERPETUAL FUTURES CONTRACTS

7 a) Orders: You have the option to place buy/sell orders for VDA derivatives traded through Pi42.com Platform using limit orders and market orders. In a limit order, you can specify the exact price at which the order is to be executed (whether or not that is the market price at the time you place the order) (“Limit Order”). In a market order, you choose to immediately buy or sell based on the price displayed on Pi42.com Platform at the time you place the order (“Market Order”). You must maintain sufficient balance in your INR Wallet before placing any orders failing which such orders may be rejected.  

7 b) Liquidation: We shall be entitled, but shall have no obligation, to make margin calls to you in respect of your transactions. If a margin call is made, it will be made through Pi42.com Platform, by email, or other electronic means. You are responsible for monitoring your Account and for maintaining sufficient margin at all times to satisfy applicable margin requirements, especially during volatile periods, regardless of whether or not a margin call has been made. Any failure to satisfy a margin call or any failure to otherwise maintain sufficient margin in your Account may lead to your positions being subject to liquidation. We shall have no liability to you or any third party in connection with any failure by you in this connection.

 8 - FEES

 

8 a) Creation of an Account on Pi42.com Platform and usage of Pi42.com Platform is free.

 

8 b) Transaction Fee: Trading on Pi42.com Platform is subject to payment of a fee on each transaction executed, which shall be chargeable on each trade basis as provided in the fee schedule as stated on Pi42.com Platform and accessible at https://pi42.com/fee-structure. By placing and confirming an order on Pi42.com Platform, you agree to pay the transaction fee.

 

8 c) Deposit Top-up of VDA in VDA Wallet address will incur fees. Top-up of INR through Instant Bank Transfer-IMPS and Manual Bank Transfer by NEFT/IMPS/RTGS is free of charge, as prescribed in the Platform. The fee applicable on withdrawal of INR shall be as provided in the Fee Structure. Top-ups and withdrawals of INR will be subject to withdrawal limits provided in the Fee Structure.

 

8 d) Payment of Fees: You authorise us and/or our designated payment processor to charge or deduct Funds from your Wallet for any applicable fees owed in connection with exchange transactions you undertake on Pi42.com Platform.

8 e) Retrieval Process Fees: We accept only one type of Crypto, i.e. USDT which is under the USDT Deposit /Conversion section on the Pi42 Platform. However, if a User makes a deposit other than USDT, we shall charge a retrieval process fee of 10% from the User, over and above the Transaction Fee.

If in the future we start accepting other Crypto, it will make changes simultaneously.

8 f) If a User deposits through any unsupported Network which is not mentioned on the USDT Deposit/Conversion section on the Pi42 Platform, the funds will be lost and cannot be retrieved. We will not be responsible for the same.

9 - NO SUITABILITY REVIEW; NO INVESTMENT ADVICE

 

9 a) No-Broker, Agent Relationship. You agree that:

i) We are the counter-party to all transactions except with regard to VDA incoming transfers into your Wallet (in which regard we merely facilitate the transaction as an intermediary) and that we do not act as your broker, agent, or advisor, or in any fiduciary capacity, and

ii) no communication or information provided to you by us shall be considered or construed as advice.

We shall carry out instructions placed by the Users through the Account on an execution-only basis. We neither manage the Account nor advises the users. We are entitled to execute a transaction placed as per User instructions even if the transaction is not beneficial for the User. Save and except and unless expressly undertaken under these Terms of Trading Policy and/or other agreement executed with the User, we are under no obligation whatsoever to monitor or advise the User on the status of any transaction, to make margin calls, or to close out any of the users’ open positions

 

9 b) You acknowledge and agree that, in the course of providing the Services to you, neither the Company nor its representatives provide any advice or recommendations regarding the purchase or sale of any VDA or VDA derivatives, nor do they make any determination of your general investment needs or objectives or of the suitability of the proposed purchase or sale of any VDA or VDA derivatives. You are responsible for your investment decisions and transactions, for any profits or losses, and for any tax consequences that may result. You further acknowledge and agree that, in the course of providing the Services to you, neither the Company nor its representatives provide you with any legal, tax, or accounting advice regarding the profitability of any VDA or VDA derivatives or investment or any decision in respect thereof, nor does the Company or its representatives consider your financial situation, investment knowledge, investment objectives, and risk tolerance when accepting orders from you. You will not solicit or rely upon any such advice from the Company or any of its employees and agree that the Company will have no liability therefore whatsoever. Additionally, the material accessible through Pi42.com Platform does not constitute a representation that the purchase of VDA or VDA derivatives is suitable or appropriate for you. Please also refer to our disclosure document available at Risk Disclosures.

 

10 - TAXES

 

10 a) It is your sole responsibility to determine, collect, report, and submit any / all taxes applicable to the payments you make or receive in connection with the use of the Services / transactions you undertake on Pi42.com Platform to the appropriate tax authority in India or under any other applicable laws. We are not responsible for determining whether any taxes apply to the transactions carried out by you on Pi42.com Platform or the Services availed by you, or for collecting, reporting or remitting any taxes arising from any transaction undertaken by you via Pi42.com Platform or Services. You acknowledge that any income from transactions involving VDAs could be treated as business income or as a capital gain, depending on the circumstances, including your trading practices. You are solely responsible for determining, reporting and submitting the applicable taxes on the income you derive from such transactions in VDAs.

 

10 b) You hereby authorize us to withhold / collect any applicable tax and deposit on your behalf in accordance with this Clause. In cases where we withhold / collect tax, we shall provide you with evidence of such withholding / collecting as per the statutory requirements. You would be solely responsible for claiming any credits, refund or exemption(s), if any, from tax authorities. We shall not be responsible in any manner whatsoever for the same. You also agree to remit to us, on demand, any additional funds if required, to discharge any such liability in relation to rewards in kind.

 

10 c) All fees, commissions, interests, and other charges of the Company are exclusive of any applicable goods and services tax which shall be borne by you and separately charged. In case any further Goods and Services Tax (“GST”) is made applicable on the Services or the transactions on Pi42.com Platform in the future, we reserve the right to separately charge such GST which shall be borne by You. You agree that VDA derivatives do not amount to 'virtual digital assets', 'goods' or 'services'.

10 d) We believe that you are a tax-compliant citizen abiding by the laws of the Income Tax Act, 1961, the GST Act, 2017, and any other applicable laws.

 

11 - TRADING, SETTLEMENT AND ACCOUNTS - TERMS AND CONDITIONS

11 a) Order Placement and Execution: You acknowledge that all orders placed through Pi42.com Platform will be subject to order execution mechanisms at our discretion. We will send online confirmation of the order execution to you via electronic mail or SMS, and this confirmation will be considered valid execution. You must promptly review all confirmations of orders, transactions, or cancellations received through electronic means and report any discrepancies to us within twenty-four hours.

 

11 b) Reporting and Account Discrepancies: Any errors in reports, confirmations, or transaction history, including execution prices, scripts, or quantities, must be brought to our notice in writing via electronic mail to [email protected] within 24 (Twenty-four) hours of receiving the concerned report. Other discrepancies in the confirmation or account should also be notified to us in writing via electronic mail to the foregoing email address within twenty-four hours of receiving the initial notice. We reserve the right to accept or reject your objections.

 

11 c) Delayed Reports and Statements: We may experience delays in generating transaction reports due to factors beyond its reasonable control. In such cases, We may forward late reports to You, and You agree not to hold us responsible for any losses resulting from such late reports or any errors in the statements received from the exchange.

 

11 d) Order Rejections and Lapses: We reserve the right to reject orders for various reasons, including non-availability of funds, VDAs margin amount, suspension of trading activities, law enforcement communications, or cyber or blockchain-related factors. If an order is not executed on Pi42.com Platform for any reason, we may consider the order as lapsed.

 

11 e) Disruptions and System Failures: You acknowledge that electronic trading systems such as Pi42.com Platform, may experience temporary disruptions, breakdowns, or failures. In the event of non-execution or cancellation of trade orders due to such events, we may cancel related requests and will not be liable for executing the desired transactions. We are not responsible for any losses incurred by you due to such disruptions beyond its control.

 

11 f) Compliance with Rules: You agree to comply with all applicable laws and with all terms and policies of the Company while transacting or otherwise using Pi42.com Platform or the Services.

 

11 h) Users Responsibility for Orders: Any order made by the User, even if mistaken, using their allotted username and credentials will be considered a valid order for which the User will be fully responsible. Cancellation or modification of orders is not guaranteed and will be processed only if the User’s request is received and executed before the order is processed.

 

11 i) Order Confirmation: You shall not presume an order as executed, cancelled, or modified until a confirmation from us is received. Delayed transmission of confirmations due to technical factors shall not entitle you to presume the status of the order without written confirmation from us.

11 j) Discretionary Trading Permissions: We may, at our sole discretion, allow or disallow you from trading in VDA derivatives or otherwise transacting on Pi42.com Platform and impose conditions as deemed fit.

11 k) Delivery: Delivery in VDA derivative contracts is different from traditional derivative contracts. As long as Users maintain sufficient margin in their Wallet at all times to satisfy applicable margin requirements for their open positions, Users can hold their long or short positions in futures contracts perpetually. Users only deal with buying and selling of contracts and the users can hold the same perpetual futures contracts indefinitely. VDA derivative contracts maintain a price close to the base price of the order known as Funding Fees and/or Premium (please refer to the Fee Structure here), by which the User gets as credit or debit in their INR Wallet.

That said, we may compel delivery of the underlying VDA in accordance with our terms and policies. Where you are the buyer in such cases, you will not be allowed to refuse taking delivery and where you are the seller, you shall not default in making delivery.