Terms, policies & disclosures.

About these terms

Effective 17 July 2026

This Legal Center sets out the terms, policies and disclosures that apply to the SINGUARD software products and to this website (together, the "Services"). The Services are provided by SGHK Softwares Limited, a company incorporated in Hong Kong (Business Registration No. 80264490), whose registered office is Flat 5, 4/F, Won Hing Building, 74–78 Stanley Street, Central, Hong Kong, trading under the brand "SINGUARD" ("SINGUARD", "we", "us" or "our"). Our trading platform is provided under the eTrader brand at etrader.sghk.org.

By accessing this website, requesting a demonstration, subscribing to any product, or otherwise using the Services, you confirm that you have read, understood and agree to be bound by these terms and policies. If you are entering into these terms on behalf of a company or other legal entity, you represent that you have authority to bind that entity, and "you" refers to that entity.

If you do not agree with any part of these terms, you must not use the Services.

We may update this Legal Center from time to time. The "last updated" date shows when the most recent changes took effect. Material changes to the Terms of Service applicable to active Licensees will be notified in accordance with the "Changes" provisions in Section 3.

Definitions

Terms of Service

Software licence & use of the Software

3.1 Nature of the Services

SINGUARD provides software and hosting only. We license our Software to Licensees as a managed, multi-tenant, white-label service. We do not provide, and the Services do not constitute, any regulated financial service, brokerage service, investment advice, market data, liquidity, custody of funds or payment service. Responsibility for how the Software is configured and operated — including branding, instrument selection, spreads, markup, commissions, challenge rules, routing decisions, and dealings with End Users — rests entirely with the Licensee.

3.2 Licence grant

Subject to your continuous compliance with these terms and payment of applicable fees, SINGUARD grants you a limited, non-exclusive, non-transferable, non-sublicensable, revocable licence to access and use the Software during your subscription term, solely for your internal business purposes and in accordance with the documentation. All rights not expressly granted are reserved by SINGUARD.

3.3 Ownership of code and data infrastructure

Our products are licensed, fully managed deployments. SINGUARD retains ownership of the source code and operates the underlying database and infrastructure. You do not receive the source code or direct database ownership; you receive brand and configuration control and access to your own data through the application and our API. You retain ownership of your Content, and grant SINGUARD a limited licence to host, process and transmit it solely to provide and support the Services.

3.4 Restrictions

You must not, and must not permit any third party to:

• copy, modify, translate, adapt or create derivative works of the Software, except as expressly permitted;
• reverse engineer, decompile or disassemble the Software, or attempt to derive its source code, save to the extent this restriction is prohibited by law;
• resell, rent, lease, sublicense, time-share or provide the Software to third parties other than your own End Users in the ordinary operation of your business;
• remove, obscure or alter any proprietary notices; or
• use the Software in breach of the Acceptable Use Policy (Section 4) or any applicable law.

3.5 Licensee responsibilities

As a condition of using the Software, each Licensee agrees that it is solely responsible for:

• obtaining and maintaining all licences, registrations and authorisations required to conduct its business in every jurisdiction in which it operates or solicits clients;
• its own regulatory compliance, including anti-money-laundering, counter-terrorist-financing, sanctions screening, KYC/onboarding, suitability, disclosure, marketing and record-keeping obligations;
• sourcing and licensing its own market data and liquidity, and for the accuracy, timeliness and legality of that data;
• all relationships with, obligations to, and communications with its End Users, including the handling and safeguarding of client money and client assets;
• the configuration of the Software (branding, instruments, pricing, challenge rules and risk parameters) and the commercial and legal consequences of those settings; and
• the security of its administrator credentials and the acts and omissions of its personnel and End Users.

3.6 Fees & payment

Fees for the Software are as set out in your order. Unless stated otherwise, fees are exclusive of taxes, duties and withholdings, and are non-refundable except where required by law. Late or failed payments may result in suspension of the Services after reasonable notice.

3.7 Intellectual property

The Software, its source code, design, structure, trademarks (including "SINGUARD" and "eTrader") and all related intellectual property are and remain the exclusive property of SINGUARD and its licensors. You retain ownership of your Content as described in Section 3.3.

3.8 Term, suspension & termination

These terms apply for as long as you use the Services or hold an active subscription. We may suspend or terminate access immediately where you materially breach these terms, fail to pay, or where continued provision would expose SINGUARD to legal, regulatory or security risk. Either party may terminate a subscription in accordance with the order terms. On termination, your licence ends and you must cease using the Software; we may delete Content after a reasonable retention period, subject to law.

3.9 Third-party services

The Software may integrate with third-party services chosen by the Licensee (for example MT4/5, cTrader, DXtrade, liquidity providers, market-data vendors, payment processors or KYC providers). SINGUARD is not responsible for those third parties, their availability, or their terms, and does not endorse or warrant them.

3.10 Changes to the Services or terms

We may modify, enhance or discontinue features of the Software, and may amend these terms, to reflect changes in technology, law or our business. We will give active Licensees reasonable prior notice of material adverse changes to the Terms of Service. Continued use after changes take effect constitutes acceptance.

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Acceptable Use Policy

Prohibited conduct on the Software

This Acceptable Use Policy ("AUP") applies to every Licensee, administrator and End User that accesses the Software. Breach of this AUP is a material breach of the Terms of Service and may result in immediate suspension or termination, and in referral to competent authorities.

4.1 You must not use the Software to

• violate any applicable law, regulation, sanctions regime or third-party right;
• operate a financial business without holding the licences and authorisations that business requires;
• facilitate money laundering, terrorist financing, fraud, market manipulation, insider dealing, "wash" or fictitious trading, or any other market abuse;
• onboard or serve any person or entity that is subject to sanctions, or that resides in a jurisdiction where your activity is prohibited;
• misrepresent SINGUARD as the provider of financial services, or state or imply that SINGUARD regulates, endorses, guarantees or is responsible for a Licensee's services or an End User's outcomes;
• upload or transmit malicious code, or attempt to gain unauthorised access to the Software, other tenants, or underlying infrastructure;
• probe, scan, load-test, or circumvent the security or access controls of the Software without our prior written consent;
• store or transmit unlawful, infringing, defamatory or harmful content; or
• interfere with or disrupt the integrity or performance of the Software or the data of any other tenant.

4.2 Enforcement

We may investigate suspected breaches and cooperate with law-enforcement and regulators. We may remove content, restrict features, or suspend or terminate access where we reasonably believe this AUP has been breached, or to protect the Software, our other customers, or third parties. Where practicable we will act proportionately and give notice, but we may act without prior notice where necessary to prevent harm or meet a legal obligation.

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Risk Disclosure & Disclaimer

Important information about trading risk

5.1 SINGUARD provides technology, not trading services

SINGUARD is software. We do not offer, solicit or execute trades, do not provide investment advice or recommendations, do not manage money, and do not guarantee any trading result. Any trading activity conducted through our Software is offered and operated by the relevant Licensee, under its own regulatory responsibility, and is between that Licensee and its End Users.

5.2 Nature of the risks

• Leverage. Margin and leverage magnify both gains and losses; small market movements can have a large impact on account equity.
• Volatility & liquidity. Prices in forex, metals, indices, CFDs and crypto-assets can move rapidly. Gaps, slippage and low liquidity can prevent orders executing at expected prices.
• Market data & execution. Pricing, quotes and execution depend on the market data and liquidity that the Licensee sources and connects. SINGUARD does not supply or warrant that data.
• Technology. No software or internet-based system is free from the risk of interruption, delay or error.
• Past performance. Past or simulated performance, including within any challenge or demo environment, is not a reliable indicator of future results.

5.3 No advice; independent decisions

Nothing on this website or in our Software is a recommendation to buy, sell or hold any instrument, or advice that any strategy is suitable for any person. End Users should assess their own circumstances, seek independent professional advice before trading, and only trade with money they can afford to lose.

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AML & Regulatory Compliance Notice

Responsibility for anti-money-laundering & licensing

SINGUARD takes financial crime seriously and provides tooling within the Software (such as configurable risk monitoring, breach detection, KYC/AML integration hooks, audit trails and reporting) that Licensees may use to support their own compliance programmes. These are software features, not a compliance, monitoring or advisory service, and they do not discharge any legal or regulatory obligation of a Licensee.

6.1 The Licensee is the regulated party

Each operating firm is solely responsible for designing, implementing and maintaining its own compliance framework, including:

• obtaining and maintaining every licence, registration or authorisation required for its activities;
• customer due diligence, KYC and ongoing monitoring of its End Users;
• anti-money-laundering (AML) and counter-terrorist-financing (CTF) controls, sanctions and PEP screening;
• transaction monitoring, suspicious-activity reporting and record-keeping under applicable law; and
• safeguarding of client money and client assets.

6.2 SINGUARD's role

SINGUARD does not onboard End Users, does not hold or move client funds, and does not act as a regulated financial institution. We do not provide legal or regulatory advice. Licensees should obtain their own professional and legal advice on the requirements that apply to them.

6.3 Cooperation

SINGUARD may suspend Services and cooperate with law-enforcement or regulators, and may disclose information where required by law or valid legal process, or where we reasonably believe the Software is being used for unlawful purposes.

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Privacy Policy

How we handle personal data

This Privacy Policy explains how SGHK Softwares Limited (SINGUARD) collects, uses and protects personal data in connection with this website and the provision of the Software to Licensees. We handle personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong and, where applicable, other data-protection laws.

7.1 Our role

For personal data of website visitors and of the business contacts of prospective and actual Licensees, SINGUARD acts as a data controller. For personal data of End Users processed within a Licensee's tenant, the Licensee is the controller and SINGUARD acts as a data processor / service provider that processes such data only on the Licensee's documented instructions to host and support the Software.

7.2 Data we collect

7.3 How we use personal data

We use personal data to provide, secure, support and improve the Services; to communicate with you about enquiries, contracts and service matters; to manage billing; to comply with legal obligations; and to protect our rights and the integrity of the Software. We do not sell personal data.

7.4 Legal bases

Where a legal basis is required, we rely on: performance of a contract (or steps to enter one); our legitimate interests in operating and securing our business; your consent (for example non-essential cookies and marketing, which you may withdraw at any time); and compliance with legal obligations.

7.5 Sharing & sub-processors

We may share personal data with trusted service providers who help us run the Services (such as hosting, infrastructure, analytics and support tools), each under appropriate confidentiality and data-protection terms; with professional advisers; and with authorities where required by law. We do not disclose Licensee tenant Content except on the Licensee's instructions or as required by law.

7.6 International transfers

Personal data may be processed or stored in jurisdictions outside your own, including at our engineering locations. Where we transfer personal data internationally, we take steps to ensure a comparable level of protection through appropriate contractual and technical safeguards.

7.7 Retention

We keep personal data only for as long as necessary for the purposes described above, to comply with legal, accounting or reporting requirements, and to resolve disputes, after which it is deleted or anonymised.

7.8 Security

We use technical and organisational measures appropriate to the risk, including access controls, encryption in transit, multi-tenant isolation and monitoring. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

7.9 Your rights

Subject to applicable law, you may request access to, correction of, or deletion of your personal data, object to or restrict certain processing, and withdraw consent. To exercise your rights, contact us at office@sghk.org. If your data is held within a Licensee's tenant, please contact that Licensee directly, as they are the controller. You may also have the right to complain to a data-protection authority, including the Office of the Privacy Commissioner for Personal Data, Hong Kong.

7.10 Children

The Services are intended for businesses and are not directed at children. We do not knowingly collect personal data from children.

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Cookie Policy

How this website uses cookies

Cookies are small text files placed on your device when you visit a website. We use them to make this site work and, with your consent, to understand how it is used. You can accept or decline non-essential cookies via the banner shown on your first visit, and you can change your browser settings at any time to block or delete cookies.

We do not use cookies for third-party advertising. If we introduce additional cookies in future, we will update this policy and, where required, ask for your consent. Declining non-essential cookies will not affect your ability to use the core parts of the site.

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Warranties, Liability & Indemnity

Please read this section carefully — it limits our liability

9.1 Disclaimer of warranties

To the maximum extent permitted by law, the Services are provided "as is" and "as available", without warranties of any kind, whether express, implied or statutory, including any implied warranties of merchantability, fitness for a particular purpose, title, accuracy and non-infringement. SINGUARD does not warrant that the Services will be uninterrupted, error-free, secure, or free from delay, or that they will meet your requirements or produce any particular commercial or trading outcome. We do not warrant any third-party market data, liquidity or integrations.

9.2 Exclusion of certain losses

To the maximum extent permitted by law, SINGUARD will not be liable for any indirect, incidental, special, consequential, punitive or exemplary damages, or for any loss of profits, revenue, goodwill, business, anticipated savings, trading losses, or loss or corruption of data, arising out of or in connection with the Services, even if advised of the possibility of such losses and regardless of the theory of liability.

9.3 Cap on liability

To the maximum extent permitted by law, SINGUARD's total aggregate liability arising out of or in connection with the Services, whether in contract, tort (including negligence) or otherwise, will not exceed the total fees paid by the Licensee to SINGUARD for the Services in the twelve (12) months immediately preceding the event giving rise to the liability.

9.4 Matters not excluded

Nothing in these terms excludes or limits any liability that cannot lawfully be excluded or limited, including liability for death or personal injury caused by negligence or for fraud or fraudulent misrepresentation.

9.5 Indemnity

You agree to indemnify, defend and hold harmless SINGUARD, SGHK Softwares Limited, their affiliates, and their respective officers, directors, employees and agents from and against any claims, liabilities, damages, losses and expenses (including reasonable legal fees) arising out of or connected with: (a) your use or operation of the Software; (b) your services to, and relationships with, your End Users; (c) your breach of these terms, the AUP, or any law or regulation; (d) your regulatory, licensing, AML/KYC or client-money obligations; or (e) any Content you or your End Users submit to the Software.

9.6 Allocation of risk

You acknowledge that the fees reflect the allocation of risk in these terms and that these limitations are an essential basis of the bargain between you and SINGUARD.

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Governing Law & Disputes

Hong Kong SAR

These terms and any non-contractual obligations arising out of or in connection with them are governed by and construed in accordance with the laws of the Hong Kong Special Administrative Region of the People's Republic of China.

The parties submit to the exclusive jurisdiction of the courts of Hong Kong to settle any dispute or claim arising out of or in connection with these terms or the Services, save that SINGUARD may seek injunctive or other equitable relief in any court of competent jurisdiction to protect its intellectual property or confidential information.

10.1 Severability & waiver

If any provision is held to be invalid or unenforceable, the remaining provisions continue in full force, and the invalid provision will be modified to the minimum extent necessary to make it enforceable. Our failure to enforce any right is not a waiver of it.

10.2 Entire agreement & assignment

These terms, together with any order or written agreement between you and SINGUARD, form the entire agreement regarding the Services and supersede prior discussions. You may not assign your rights without our written consent; we may assign to an affiliate or in connection with a merger, acquisition or sale of assets.

10.3 Force majeure

Neither party is liable for failure or delay caused by events beyond its reasonable control, including acts of God, outages, network or infrastructure failures, cyber-attacks, government action or civil disturbance.

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Contact

For any questions about these terms, our policies, or to exercise a data-protection right, please contact:

SGHK Softwares Limited (SINGUARD) · Business Registration No. 80264490
Flat 5, 4/F, Won Hing Building,
74–78 Stanley Street, Central, Hong Kong.
Email: office@sghk.org

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