This Master Account Agreement and any exhibits attached hereto (this “Agreement”) is entered into as of the date of Analyst’s Consent (as defined herein)(the “Effective Date”) by and between Bulenox, LLC, a Delaware limited liability company (“Bulenox” or the “Company”) and the party to be bound by this Agreement (“Analyst”). Capitalized terms that are not defined herein shall have the meaning given to such terms as set forth in the Terms of Use.
WHEREAS, Bulenox is a training and education business that provides and maintains access to one or more online platforms as set forth in Exhibit A (each, a “Trading Platform” and collectively, the “Permitted Trading Platforms” – see Exhibit A for an exhaustive list) providing Analyst with access to certain educational resources, analytical tools, financial and market information, simulated trading software and other related services (collectively, the “Services”);
WHEREAS, Analyst established a Qualification Account and purchased access to certain Services through a Trading Platform;
WHEREAS, Analyst has achieved the objectives set forth in that certain Qualification Account Agreement entered into by and between Bulenox and Analyst;
WHEREAS, Bulenox desires to grant Analyst access to a trading account (a “Master Account”) in which (i) Analyst will have the ability to engage in simulated trades of commodity futures using simulated capital, including but not limited to any simulated profits generated (“Virtual Currency”) and (ii) Analyst will have the opportunity to earn a financial reward based on the results of such simulated trades using Virtual Currency and in accordance with the terms and conditions of this Agreement and Exhibit A attached hereto (the “Reward”);
WHEREAS, Bulenox values the trading data generated by Analyst in the Master Account (the “Trading Data”) and considers such Trading Data to be sufficient consideration to offer and pay the Reward.
NOW, THEREFORE, in consideration of the mutual covenants and agreements set forth herein and for other good and valuable consideration, the receipt and sufficiency of which is hereby acknowledged, the parties hereto agree as follows:
1. MASTER ACCOUNT
1.1 Access to Master Account
Subject to the terms of this Agreement, Bulenox shall provide Analyst access to the Master Account upon payment of a one-time, non-refundable activation fee based on the selected account size, as set forth in Exhibit A attached hereto (“Account Fees”).
1.2 Personal ID
Analyst acknowledges that, once Bulenox provides Analyst access to the Master Account and Services therein, Analyst shall trade only using Analyst’s Account (defined in Terms of Use). Analyst shall keep Analyst’s Account information confidential and such information shall be subject to Sections 3 and 4 of this Agreement.
2. REPRESENTATIONS, WARRANTIES, AND COVENANTS
Analyst represents, warrants, and covenants to Bulenox as follows:
Analyst acknowledges and agrees:
No performance provided by Bulenox to Analyst under this Agreement, including any Services, may be considered as investment services or activities within the meaning of the legal regulations governing, in particular, investment services and capital markets. Bulenox does not receive or execute in any case, whether directly or indirectly, any trading instructions, does not trade on its own account, does not provide or conduct investment or other advice, research, recommendations or analyses, does not give or forward to Analyst any trading instructions, does not receive any assets from, or manage any assets for, Analyst, and does not provide any related market or exchange services.
No employees or other staff or representatives of Bulenox are authorized to provide services within the meaning of Section 2(a)(i).
All trading that Analyst performs through Analyst’s Master Account is simulated only, and the execution of a simulated trade within the Services provided shall in no way constitute an instruction to trade in actual financial markets or with real currency.
Virtual Currency is not real currency and Analyst has no right to it beyond the scope of its use in connection with the Master Account and the Services (in particular Virtual Currency cannot be used for actual trading), Analyst is not entitled to withdraw or transfer any Virtual Currency, and Bulenox does not in any circumstance receive any funds or other assets from, or manage any funds or other assets for, Analyst within the Services.
Performance of the Master Account is not indicative of trading in actual financial markets, and past performance and any earned Reward are neither a guarantee nor an indication of any future performance.
If Analyst’s access to the Master Account is canceled for any or no reason (including Account Inactivity as described in Exhibit A), Analyst shall lose access to the Master Account and the Services, without being entitled to any compensation.
Excessive or unrealistic single day or single trade profits or other conduct not permitted by this Agreement will be subject to review by Bulenox for any possible violations of this Agreement.
Analyst is obligated to maintain accurate and current identifying information, and Analyst shall promptly notify Bulenox about and provide Bulenox with Analyst’s accurate and correct identifying information upon request by Bulenox. Any failure to provide accurate information shall be a material breach of this Agreement.
In performing this Agreement, Analyst shall (i) comply with all applicable legal regulations; (ii) if required under applicable law, obtain, and maintain the validity of, all permits, licenses, consents, or approvals, which may apply to Analyst’s activities under this Agreement; and (iii) fulfill all notification, tax, fee, or other obligations that may arise in connection with the performance of this Agreement, and in particular with the Reward. Analyst is authorized to access and use the Services only in accordance with the applicable legal regulations and is prohibited from circumventing any measures (technical or otherwise) that may limit the availability of the Services in certain countries. In no event shall Bulenox bear any responsibility for the failure of Analyst to fulfill any of its obligations under this Agreement.
Analyst hereby acknowledges that the Virtual Currency has no monetary value and is only a part of the Services provided to Analyst and Analyst has no actual right, title, or ownership to such Virtual Currency, and that Bulenox has all rights, interest, and full ownership to all Virtual Currency (as part of the Services). The Master Account and any and all rights related to the Services that are granted by this Agreement are personal to Analyst and cannot be transferred by contract or otherwise.
Analyst represents that Analyst:
has never been convicted of (1) any felony, or (2) any misdemeanor related to fraud, dishonesty, false statements or wrongful taking of property;
has never been disciplined or the subject of an action by any governmental or self-regulatory organization, including but not limited to the National Futures Association (“NFA”) or the Commodity Futures Trading Commission; and
has no outstanding debts with a clearing firm or other financial services firm.
Identity, Eligibility, Sanctions, and Payment Accuracy:
Analyst represents, warrants, and covenants that all information submitted to Bulenox, including name, address, date of birth, tax classification, payment information, payout instructions, and residency information, is true, complete, current, and belongs to Analyst personally or to a verified business entity approved by Bulenox in writing.
Analyst shall not submit third-party payment information, third-party bank accounts, payment accounts controlled by another person, or payment instructions inconsistent with Analyst's verified identity unless Bulenox has expressly approved such arrangement in writing after completing any required verification. Any identity mismatch, suspected straw-person arrangement, sanctions concern, or third-party payout instruction may result in a payout hold, additional documentation request, denial of the payout request, suspension, or termination.
Analyst is not located in, ordinarily resident in, or accessing the Services from any jurisdiction where Bulenox is prohibited from offering the Services by law, sanctions program, exchange rule, payment processor restriction, platform provider restriction, or Bulenox policy. Analyst shall immediately notify Bulenox of any change in residency, tax status, citizenship, payment information, or legal capacity that may affect eligibility for the Services or Rewards.
3. ACCOUNT OWNERSHIP
Any assets or funds in the Master Account are the sole property of Bulenox and its partners. Analyst acknowledges and agrees that all managed simulated accounts are under exclusive rights and fully belong to Bulenox and its partners.
Bulenox has the right, in its sole and absolute discretion, to move Analyst to a different identifying simulated account at any time and without notice.
4. ACCOUNT RULES
All Master Accounts and Services are subject to the account rules set forth in Exhibit A attached hereto (“Account Rules”). Analyst acknowledges and agrees that Analyst is solely responsible for staying current on Account Rules, which remain subject to change at any time, with or without notice, as set forth in Section 23 herein. Analyst acknowledges and agrees that Account Rules are subject to change by Bulenox in its sole and absolute discretion.
5. INDEMNIFICATION
Analyst shall defend, indemnify and hold Bulenox, its subsidiaries, and affiliates, and its respective officers, agents, partners, and employees, harmless from and against, any loss, damage, liability, claim, or demand, including reasonable attorney’s fees and expenses, made by any third party due to or arising out of Analyst’s contributed content, use of Bulenox Services, and/or arising from a breach of this Agreement and/or any breach of Analyst’s representations or warranties set forth herein. Notwithstanding the foregoing, Bulenox reserves the right, at Analyst’s expense, to assume the exclusive defense and control of any matter for which Analyst is required to indemnify Bulenox, and Analyst agrees to cooperate, at Analyst’s sole expense, in Bulenox's defense of such claims. Bulenox will use reasonable efforts to notify Analyst of any such claim, action, or proceeding which is subject to this indemnification upon becoming aware of the same.
6. LIMITATIONS OF LIABILITY
IN NO EVENT SHALL BULENOX OR ITS DIRECTORS, EMPLOYEES, OR AGENTS BE LIABLE TO ANALYST OR ANY THIRD PARTY FOR ANY DIRECT, INDIRECT, CONSEQUENTIAL, EXEMPLARY, INCIDENTAL, SPECIAL, OR PUNITIVE DAMAGES, INCLUDING LOST PROFIT, LOST BUSINESS OPPORTUNITY, LOST REVENUE, LOSS OF DATA OR OTHER DAMAGES ARISING FROM ANALYST’S USE OF THE SITES OR THE SERVICES, EVEN IF BULENOX HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. NOTWITHSTANDING ANYTHING TO THE CONTRARY CONTAINED HEREIN, BULENOX’S AGGREGATE LIABILITY TO ANALYST FOR ANY CAUSE WHATSOEVER AND REGARDLESS OF THE FORM OF THE ACTION, WILL AT ALL TIMES BE LIMITED TO THE AMOUNT PAID, IF ANY, BY ANALYST TO BULENOX FOR THE SERVICES DURING THE PERIOD OF 30 DAYS PRIOR TO THE ARISING OF ANY CAUSE OF ACTION.
ANALYST ACKNOWLEDGES THAT THE SERVICES BEING PROVIDED HEREUNDER INCLUDE BULENOX’S UTILIZATION OF VARIOUS LICENSES AND REQUIRE BULENOX TO ENTER INTO AGREEMENTS WITH THIRD PARTIES. BULENOX SHALL HAVE NO LIABILITY, DIRECTLY OR INDIRECTLY, FOR ANY DAMAGE OR LOSS CAUSED OR ALLEGED TO BE CAUSED BY OR IN CONNECTION WITH USE OF OR RELIANCE ON ANY SUCH CONTENT, SERVICES OR SOFTWARE AVAILABLE THROUGH ANY SUCH LICENSES OR THIRD-PARTY AGREEMENTS. MOREOVER, AT ANY TIME, THIRD PARTIES MAY DETERMINE, IN THEIR SOLE DISCRETION, TO AMEND APPLICABLE TERMS AND CONDITIONS AND/OR STOP PROVIDING SUCH SERVICES OR STOP GRANTING LICENSES TO SUCH SOFTWARE ALTOGETHER, WHICH MAY RESULT IN THE SERVICES BULENOX PROVIDES TO ANALYST NO LONGER BEING COST FEASIBLE OR PRACTICABLE FOR BULENOX TO CONTINUE PROVIDING THE SERVICES TO ANALYST.
CERTAIN STATE LAWS DO NOT ALLOW LIMITATIONS ON IMPLIED WARRANTIES OR THE EXCLUSION OR LIMITATION OF CERTAIN DAMAGES. IF THESE LAWS APPLY TO ANALYST, SOME OR ALL OF THE ABOVE DISCLAIMERS OR LIMITATIONS MAY NOT APPLY TO ANALYST, AND ANALYST MAY HAVE ADDITIONAL RIGHTS. IF ANALYST IS A CALIFORNIA RESIDENT, ANALYST WAIVES CALIFORNIA CIVIL CODE SECTION 1542, WHICH SAYS: "A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS WHICH THE CREDITOR DOES NOT KNOW OR SUSPECT TO EXIST IN HIS OR HER FAVOR AT THE TIME OF EXECUTING THE RELEASE, WHICH, IF KNOWN BY HIM OR HER MUST HAVE MATERIALLY AFFECTED HIS OR HER SETTLEMENT WITH THE DEBTOR.”
7. PERFORMANCE CONSISTENCY
Bulenox’s goal, under the right circumstances, is to build a long-term partnership with Analyst. Therefore, Analyst shall implement a logical and systematic approach to trading activity. Any manipulative trading strategy or scheme, whether through a single trade or multiple trades, that attempts to generate a substantial profit in violation of any Risk Parameter (as defined in Exhibit A) may result in the immediate termination by Bulenox of this Agreement and all related Services. . However, Analyst must have an average position size that does not exceed the average during the qualification process.
Master Account is subject to a forty percent (40%) Consistency Rule for each Reward Cycle.
The Consistency Percentage shall be calculated using the following formula:
Consistency Percentage = (Highest Net Profitable Trading Day ÷ Total Net Profit Generated During the Applicable Reward Cycle) × 100
For purposes of this Agreement, “Highest Net Profitable Trading Day” means the highest net profit generated by the Analyst during any single trading day within the Applicable Reward Cycle.
“Total Net Profit Generated During the Applicable Reward Cycle” means the total Net Profit generated in the Account during the period commencing immediately following the preceding Reward and ending upon submission of the applicable Reward request.
If the Account does not satisfy the forty percent (40%) Consistency Requirement at the time a Reward request is submitted, such failure shall not, by itself, constitute a breach of this Agreement or result in termination or closure of the Account. The Trader may continue trading the Account until the Consistency Percentage satisfies the applicable requirement, provided that no other provision of this Agreement is violated.
Bulenox may exclude from the consistency calculation any trades that are reversed or canceled, are determined to have resulted from a platform-wide error, or are determined to violate this Agreement or any applicable trading rules.
Bulenox expects Analyst to employ a consistent, legitimate trading strategy. Relying on significant trading days and then "flipping" contracts merely to meet the required trading days for withdrawal eligibility is prohibited and may result in the denial or delay of payout requests or Reward until consistency is demonstrated. Analyst must not exceed 20% of trading days within the applicable payout period that could reasonably be classified as flipping.
For purposes of this Agreement, "Flipping" refers to placing a trade primarily or solely to count as a "trading day" for withdrawal eligibility, rather than executing trades in alignment with a consistent, disciplined day-to-day strategy. Without limiting the foregoing, a trading day may be considered a Flipping when it materially deviates from the Analyst’s typical trading behavior, including, without limitation, any Analyst’s behavior demonstrated in Qualification Account activity and/or during the profit-generating days of a payout period. For the avoidance of doubt, using a minimum contract size relative to the Analyst’s normal position size, placing trades with unusually short holding times inconsistent with the Analyst’s typical strategy, generating nominal PnL that reasonably appears intended only to “create a day,” and exhibiting a repeated pattern of such trades after a large profitable day or immediately prior to a withdrawal request may be considered Flipping. Any trades or trading days suspected of being Flipping may require validation, including chart markups showing the precise entry criteria for each trade and similar entries from previous days that follow the same rules. This validation ensures the trade aligns with a regular trading approach, rather than Flipping.
“Flipping Percentage” is calculated as: Flipping Percentage (%) = (Number of Flip Days ÷ Total Trading Days in the applicable payout period) * 100. The Flipping Percentage must be 20% or less at the time a payout request is submitted.
The following examples are provided for illustrative purposes only. Bulenox expressly reserves all rights and retains the sole and exclusive discretion to review, assess, interpret, and determine the nature of Analyst’s trading activity:
Large Profit Day + Placeholder Days. Analyst generates a substantial portion of the payout period’s profit on one or a small number of trading days (frequently through an increased position size), and thereafter executes one or more minimum-contract trades on subsequent days primarily to qualify such days as trading days for withdrawal eligibility, resulting in token or nominal PnL and/or trading activity inconsistent with Analyst’s prior demonstrated trading strategy.
“Touch Trades” / Seconds-Long Trades. Analyst repeatedly enters and exits positions within seconds or otherwise holds positions for an unusually short duration relative to the Analyst’s typical trading approach, particularly using minimum-contract size, resulting in near-breakeven or nominal PnL that appears intended solely to “create a day” (i.e., qualify as a trading day for withdrawal eligibility).
End-of-Day “Check-In” Trades. Analyst executes in one small or a small number of trades near the close of a session or immediately before submitting a payout request, using minimum-contract size and generating nominal PnL, where the observable timing and pattern indicates the primary intent is to satisfy trading day eligibility requirements, rather than to execute strategy-consistent trades.
Instrument/Contract Switching to Minimize Exposure. Upon generating meaningful profits, Analyst begins trading materially lower-exposure instruments (such as transitioning from standard to micro contracts or otherwise reducing notional exposure) and conducts trades yielding only nominal PnL, where the observable pattern indicates that primary intent is to satisfy trading day requirements rather than to execute strategy-consistent trades.
Abrupt Strategy Discontinuity Without Support. Analyst’s post-profit trading days display a material deviation from Analyst’s previously demonstrated trading method (including, without limitation, changes to position size, holding time, or entry criteria) and Analyst cannot provide adequate, objective validation demonstrating that the trades were executed pursuant to a consistent strategy.
Analyst may not use minimum-exposure trades, seconds-long trades, instrument switching, contract-size reduction, offsetting activity across accounts, or any other pattern that appears primarily designed to satisfy Trading Day requirements, reduce calculated consistency percentages, or otherwise evade the spirit of the Account Rules.
8. ACCOUNT CYCLING
Analyst shall not engage in Account Cycling. For purposes of this Agreement, "Account Cycling" means any pattern of conduct, including repeat payout-failure conduct, whether occurring in one account or across multiple accounts, in which Analyst, directly or indirectly, opens, purchases, activates, resets, replaces, re-registers for, or otherwise obtains access to one or more Qualification Accounts, Master Accounts, Fast-Track Master Accounts, Momentum Qualification Accounts, Momentum Master Accounts, Funded Accounts, or related accounts; receives one or more Rewards, payouts, withdrawals, credits, or other economic benefits; and thereafter fails, breaches, abandons, terminates, allows to become inactive, materially reduces trading activity in such account or accounts, declines or rejects an offered Funded Account transition or activation without a legitimate business or personal reason, or otherwise engages in conduct that Bulenox determines, in its sole and absolute discretion, is inconsistent with disciplined, long-term trading, creates excessive payout or operational risk, or is intended to exploit the commercial structure of the Services.
Bulenox may determine whether Account Cycling has occurred based on the totality of the circumstances, including, without limitation, Analyst's current and historical account activity; the number of accounts opened, purchased, activated, reset, failed, breached, abandoned, terminated, or allowed to become inactive; the timing, frequency, and amount of Rewards received; the number of trading days before and after each Reward; whether an account was failed, breached, abandoned, terminated, or allowed to become inactive shortly after a Reward; whether Analyst has repeatedly declined or rejected eligibility for a Funded Account after receiving Rewards or becoming eligible for transition; Analyst's payout-to-fee ratio; Analyst's use of discounts, promotions, resets, or new account purchases following prior Rewards; trading behavior before and after each Reward; position sizing, drawdown usage, consistency, Flipping, risk-management, and strategy-validation history; account inactivity; chargebacks, payment disputes, refund requests, or payment reversals; and any accounts, activity, persons, entities, devices, IP addresses, payment methods, payout destinations, Rithmic User IDs, trading infrastructure, trading patterns, or other identifiers that Bulenox determines, in its sole and absolute discretion, to be related, coordinated, commonly controlled, or commonly benefited.
Without limiting the foregoing, the following may constitute evidence of Account Cycling: (i) receiving one or more Rewards and thereafter failing, breaching, abandoning, terminating, allowing an account to become inactive, or materially reducing trading activity in the same account within a short period of time; (ii) repeatedly obtaining new accounts after prior accounts generated Rewards and were subsequently failed, breached, abandoned, terminated, or allowed to become inactive; (iii) materially increasing risk, position size, drawdown usage, or otherwise materially departing from prior trading behavior after receiving a Reward; (iv) using multiple accounts, resets, promotions, discounts, household accounts, related entities, nominees, coordinated persons, or common payment methods to multiply Reward opportunities or continue an Account Cycling pattern; (v) generating Rewards from one or a small number of highly profitable trading days and thereafter engaging in nominal, placeholder, Flipping, or materially reduced trading activity; (vi) repeatedly declining or rejecting eligibility for a Funded Account transition or activation while continuing to purchase or participate in Qualification Accounts or Master Accounts or Fast-Track Master Accounts or Momentum Qualification Accounts or Momentum Master Accounts, where such conduct forms part of a broader pattern of Reward extraction or Account Cycling; or (vii) any other conduct that Bulenox determines, in its sole and absolute discretion, is designed or likely to extract Rewards while avoiding the disciplined, long-term trading relationship contemplated by this Agreement.
If Bulenox determines, in its sole and absolute discretion, that Analyst has engaged in Account Cycling or that Analyst's account history is inconsistent with disciplined, long-term trading, Bulenox may impose one or more restrictions, conditions, or remedies, including, without limitation: requiring manual approval before any new account purchase, activation, reset, Fast-Track Master Account or Momentum Master Account or Master Account activation; imposing a cooling-off period, meaning a temporary restriction during which Analyst may not purchase, activate, or otherwise obtain any new Qualification Accounts, Master Accounts, Fast-Track Master Accounts, Momentum Qualification Accounts, Momentum Master Accounts, Funded Accounts, or any other accounts offered through the Services; limiting Analyst to one active account; reducing maximum Reward amounts; increasing minimum trading-day or profitable-trading-day requirements; imposing enhanced consistency, Flipping, risk-management, or strategy-validation requirements; requiring additional documentation, trade rationale, chart markups, platform records, or other supporting evidence; delaying, reducing, denying, or conditioning pending or future Rewards; excluding Analyst from discounts, promotions, bundles, free resets, courtesy credits, or special offers; requiring enhanced risk review or Funded Account review; suspending, closing, restricting, or terminating one or more related accounts; restricting Analyst from future account purchases or activations; or terminating Analyst's participation in the Services.
Bulenox shall have no obligation to continue offering new accounts, resets, promotions, discounts, courtesy credits, Master Account activations, or additional simulated-account opportunities to any Analyst whose account history reflects repeated Reward extraction followed by account failure, breach, abandonment, termination, inactivity, excessive-risk trading, or other Account Cycling behavior. Nothing in this Section shall limit any other right or remedy available to Bulenox under this Agreement, the Account Rules, the Terms of Use, applicable law, or any other applicable policy.
For greater certainty, ordinary trading losses, a single account failure shall not, by themselves, automatically constitute Account Cycling. Bulenox may distinguish between ordinary trading losses and a repeated pattern of Reward extraction followed by account failure, breach, abandonment, termination, inactivity, repeated rejection of Funded Account transitions, or excessive-risk trading. In making such determination, Bulenox may consider objective account records, trading data, payment history, risk reviews, and any other facts or circumstances that Bulenox determines, in its sole and absolute discretion, to be relevant.
9. TRADING DISCLOSURES
Bulenox is not liable for any claims of damages for loss of profits or loss of other intangibles caused by internet connection failures or slow-downs, software failures, or Analyst’s hardware. Any software, platform or data feed (“Data Feed”) is subject to possible software lags or errors. Analyst should consider whether trading or investing is the right fit for Analyst based on his or her trading objective and level of experience. By choosing and engaging with any of Bulenox’s programs and contents, Analyst accepts all liability and risks. Futures trading have large potential rewards but also have large potential risks. Analyst must be aware of the risks and be willing to accept them in order to invest in the futures markets.
Bulenox is not responsible or liable for any loss or damage or expense incurred by Analyst in relation to, or directly or indirectly arising from, but not limited to:
Any error or failure or interruption or disconnection in the operation of a Trading Platform(s) or other third party Data Feed or trading software (each, a “Trading Tool”), or any delay caused by a Trading Platform or Trading Tool or transactions made via a Trading Platform, any technical problems, system failures, and malfunctions, communication line failures, equipment or software failures or malfunctions, system access issues, system capacity issues, high internet traffic demand, security breaches, and unauthorized access, and other similar computer problems and defects.
Unauthorized third persons having access to information, including electronic addresses, electronic communication, personal data, and access data, when the above are transmitted between the parties hereto or any other parties using the internet or other network communication facilities, post, telephone, or any other electronic means.
Any failure by Bulenox to perform any of its obligations under this Agreement as a result of Force Majeure Event or any other cause beyond its control.
10. TRADING PLATFORMS AND FEES
Analyst with an active Master Account is solely responsible for fees associated with a Trading Platform or Trading Tool and is obliged to pay all costs associated with using a Trading Platform or Trading Tool. Analyst shall use only the Permitted Trading Platforms and Permitted Trading Tools (as set forth in Exhibit A) that have been approved by Bulenox for Analyst's use only. Bulenox does not own these Permitted Trading Platforms or Permitted Trading Tools and only provides access of use of the same to Analyst through a license grant and/or third-party agreement.
Analyst acknowledges and understands that the use of an unsupported and/or unapproved Trading Platform or Trading Tool is strictly prohibited by Bulenox. An unsupported Trading Platform includes any third-party (or API-execution) platform or third-party (or API-execution) Data Feed or software not expressly included in Exhibit A as Permitted Trading Platforms or Permitted Trading Tools. Analyst further agrees that Analyst’s Account will be subject to immediate suspension and Bulenox reserves the right to refuse any claim to a Reward if Analyst uses an unauthorized and unapproved Trading Platform or Trading Tool.
If Analyst elects to use a Trader Composite Software, Analyst shall be required to pay a Third-Party API/Trader Composite Software fee of one hundred dollars ($100) per month. Payment of this fee permits direct connectivity to the Rithmic platform through a third-party API or Trader Composite interface.
Analyst acknowledges and agrees that Rithmic actively monitors platform and market data usage. Any misuse, excessive polling, unauthorized activity, or high-frequency automated trading activity may result in the suspension, restriction, or automatic disabling of data access by Rithmic, in its sole discretion.
Analyst further acknowledges that any Third-Party API or Trader Composite Software is provided and operated by independent third-party providers outside of Bulenox’s control. Bulenox makes no representations or warranties regarding the availability, functionality, performance, reliability, or security of such third-party software and shall not be held responsible or liable for any errors, malfunctions, outages, data issues, trading disruptions, or any other consequences arising from the use of such third-party software.
Bulenox shall not be responsible or liable for any losses, damages, interruptions, trading disruptions, or other adverse consequences arising from or related to any suspension, restriction, disabling, or termination of data access or services by Rithmic, or the use, misuse, failure, or malfunction of any Third-Party API or Trader Composite Software.
Analyst shall not use any virtual private network (“VPN”), virtual private server (“VPS”), proxy server, IP-masking tool, or any other technology or method designed to obscure or alter Analyst’s actual geographic location or IP address when accessing the Master Account or any Permitted Trading Platform or Permitted Trading Tool. Analyst must access the Master Account and any Permitted Trading Platform or Permitted Trading Tool through a legitimate, unmasked, and verifiable IP address. Any use of a VPN or any similar technology constitutes a material violation of this Agreement and may result in immediate suspension or termination of Analyst’s Account and forfeiture of any Reward, in Bulenox’s sole and absolute discretion.
Analyst’s Account and trade executions are subject to broker commission, routing, exchange, and NFA Fees. Commissions are subject to change.
11. ALGORITHMIC AND AUTOMATED TRADING AND TRADE COPYING
Analyst shall not abuse the Services. This prohibition includes but is not limited to using “scalping” algorithms, DTC Protocol, API, and/or other automated discretional trading in any of the trading environments. Analyst shall not open and close hundreds or thousands of rapid trades by using any trading algorithms. Analyst shall not implement reckless transactions in rough markets to benefit from lack of execution. If Analyst abuse is suspected, Bulenox reserves the right to refuse any claim to a Reward by Analyst. In order to avoid performance discrepancy and/or meet compliance regulations, any third-party algorithms must be approved by the Bulenox management team.
The trade copying functionality is exclusively available for accounts operating within the same company. Copying trades from accounts belonging to other companies is strictly prohibited. This policy also extends to copying trades from accounts within Bulenox’s system to those belonging to other companies. Analyst is permitted to copy trades only between accounts provided by Bulenox.
Analyst is solely responsible for all trades, orders, cancellations, modifications, executions, rejected orders, duplicate orders, copied trades, software malfunctions, connectivity failures, platform settings, and account-linking decisions generated through any Trading Platform, Trading Tool, trade copier, algorithm, script, hotkey, add-on, plug-in, API connection, or other technology used by Analyst, regardless of whether the resulting activity was intentional, accidental, or caused by third-party software.
Any cross-company copying, mirror trading with another person, group trading, account-passing, use of another person's strategy as a managed service, or coordinated trading activity designed to replicate trades among multiple users may be treated as a material breach and may result in payout denial, account suspension, termination, or forfeiture of Rewards in Bulenox's sole discretion.
12. REWARDS
In connection with Analyst’s Master Account activity, Analyst shall be entitled to certain Rewards subject to the rules set forth in Exhibit A. To collect a Reward, Analyst must submit a withdrawal request through a personal profile on Bulenox.com. Before the first request, Analyst must fill out and send a Tax Form, Withdrawal Information Form, and attached government issued ID to HelpDesk “Withdrawal Forms” category.
Subject to the provisions of this Agreement, Analyst's Account must be in net profit over the initial balance. Analyst shall be entitled to a percentage of safety threshold reserves as set forth in Exhibit A upon the termination of this Agreement.
Bulenox shall not be obligated to pay more than the maximum Reward allowed per payment period, or to disburse any amounts that have not yet met the qualified requirements outlined in this Agreement and Exhibit A thereto, in the event of a termination request.
Submission of a Reward request does not create an unconditional right to payment. Bulenox may review, delay, reduce, reject, or request additional documentation for any Reward request if Bulenox reasonably determines that additional review is needed to verify compliance, identity, tax status, payout instructions, trading data, platform records, or suspected prohibited conduct.
Bulenox may require Analyst to provide trade rationale, chart markups, timestamps, trading plan, screenshots, platform logs, bank/payment verification, tax documents, government identification, proof of address, or other documentation reasonably requested by Bulenox. Failure to provide complete and accurate documentation within the requested time may result in denial or delay of the Reward request.
Bulenox may withhold, offset, or suspend payment of any Reward to the extent required by law, tax reporting obligations, payment processor restrictions, sanctions screening, chargeback review, fraud review, platform-provider restriction, or unresolved dispute involving Analyst's account or payment history.
If a Reward payment issued by Bulenox is returned, rejected, declined, reversed, or otherwise fails to be completed due to incorrect or incomplete withdrawal information provided by Analyst, incorrect address information, an incorrectly specified Master Account, inaccurate banking details, the receiving bank's refusal to accept the payment, the receiving institution's inability or refusal to accept payments in U.S. Dollars (USD), or any similar reason not attributable to Bulenox, Bulenox reserves the right to deduct a reprocessing fee of fifty dollars ($50) from any subsequent reissuance of the same Reward payment. Such fee shall be applied each time a payment must be reissued due to any of the foregoing circumstances
Rewards may be requested via ACH/Wire Transfer or Paypal. Bulenox at its sole discretion may make a payment from any account at any time in any amount.
Rewards may be requested anytime during the calendar month. All rewards are processed once per week, on Wednesdays. The reward request must be submitted via “Payout Request Form” by the end of Friday before 11:59 p.m. ET. All reward requests submitted after 12:00 a.m. ET will process Wednesday of the following week.
The request for any reward may be processed after Analyst has completed at least ten (10) or more individual trading days. The trading day will count as completed once the market closes. The second, the third, and the following withdrawals will be counted from the payout date.
Bulenox will pay Analyst ninety percent (90%) of all profits eligible for withdrawal, with the remaining ten percent (10%) retained by Bulenox.
The minimum withdrawal amount for the first three (3) Rewards is $1,000. For a $10,000 Account, the minimum withdrawal amount is $500.
For the first three (3) Rewards, the maximum Reward amount permitted per Reward request depends on the Account size, as follows:
$10,000 Account — $750
$25,000 Account — $1,000
$50,000 Account — $1,500
$100,000 Account — $1,750
$150,000 Account — $2,000
$250,000 Account — $2,500
After the third (3rd) Reward, Analyst may not request a Reward in an amount exceeding fifty percent (50%) of the Total PnL of the Account at the time the Reward request is submitted. The fifty percent (50%) limitation applies to every Reward request, including Reward requests submitted after the third (3rd) Reward.
Analyst must comply with the withdrawal safety threshold reserve (STR) limits. The withdrawal safety threshold reserve is defined as the minimum amount required to remain in the Analyst’s Account to be able to withdraw, as follows.
$10,000 Account - STR $1,100
$25,000 Account - STR $1,600
$50,000 Account - STR $2,600
$100,000 Account - STR $3,100
$150,000 Account - STR $4,600
$250,000 Account - STR $5,600
13. FUNDED ACCOUNT TRANSITION
13.1 Funded Account Transition
Upon the completion of three (3) successful Rewards under any Master Account, and subject to the sole discretion of Bulenox’s Risk Management Department (“Risk Management Department”), Analyst shall be eligible to transition such Master Account to a live commodity futures trading account (“Funded Account”). The Funded Account transition shall be governed by the terms and conditions of the applicable funded account agreement (“Funded Account Agreement”), under which Analyst will be deemed bound as a party thereto (“Trader”) and thereby permitted to trade with real currency.
An Analyst may maintain up to five (5) active Funded Accounts, provided that such Funded Accounts correspond to Master Accounts that were active and eligible for transition at the time of the initial transition to Funded Account status.
Upon the transition of any Master Account to a Funded Account, no additional Master Accounts may be activated. Accordingly, any Master Account that has not been activated at the time of such transition shall remain in pending status and shall not subsequently be activated while any Funded Account remains active.
Where multiple Master Accounts are active at the time the Analyst becomes eligible for transition, each such Master Account shall be evaluated individually for transition eligibility:
A Master Account from which three (3) successful Rewards have been completed shall be eligible for transition to a Funded Account, subject to the sole discretion of the Risk Management Department.
Any other active Master Account from which at least one (1) successful Reward has been completed shall also be eligible for transition to a separate Funded Account, subject to the sole discretion of the Risk Management Department.
Any active Master Account from which no successful Reward has been completed shall not be eligible for transition and shall not be transferred or converted into a Funded Account.
Any Master Account in pending status at the time of transition shall remain pending and shall not be activated while any Funded Account remains active.
Each eligible Master Account shall transition to a separate Funded Account. Funded Accounts shall not be consolidated with one another, and each Funded Account shall correspond to a single Master Account.
If Analyst does not consent to the transition to a Funded Account, the applicable Master Account shall be closed, and no further Reward shall be issued from such Master Account.
13.2 Funded Account Starting Balance and Risk Parameters
Each Funded Account shall instead be assigned an initial End-of-Day drawdown risk parameter (“Initial EOD Drawdown”) based on the corresponding Master Account type, as follows:
Master Account Type Initial EOD Drawdown
$25,000 Master Account US $1,500
$50,000 Master Account US $2,000
$100,000 Master Account US $3,000
$150,000 Master Account US $4,500
The Initial EOD Drawdown constitutes a risk-management parameter applicable to the Funded Account and does not represent a balance, profit contribution, credit, or amount transferred from the corresponding Master Account.
14. MULTIPLE ACCOUNTS
Analyst may simultaneously maintain multiple Qualification Accounts and Master Accounts, subject to the limitations set forth herein. Analyst may have no more than five (5) Master Accounts in total, including Fast-Track Master Accounts and Momentum Master Accounts. All Accounts created or maintained by Analyst must be associated with the same Rithmic User ID. Master Accounts may not be consolidated into a single, larger account.
All positions in the same instrument and all equity index instruments across all Master Accounts, Fast-Track Master Accounts, and Momentum Master Accounts must be maintained and executed in a uniform directional manner. This requirement applies to both Standard and Micro contracts. For example, if Analyst holds one (1) NQ long contract in a Master Account, Fast-Track Master Account, or Momentum Master Account, Analyst may only open or maintain long positions in NQ or MNQ in any other Master Account, Fast-Track Master Account, or Momentum Master Account. Analyst may not open a short position in NQ or MNQ until the one (1) NQ long contract has been closed. Similarly, if Analyst holds one (1) NQ long contract and one (1) ES long contract across any Master Account, Fast-Track Master Account, or Momentum Master Account, Analyst may only maintain or open long positions in NQ, MNQ, ES, MES, or any other equity index instrument across any Master Account, Fast-Track Master Account, or Momentum Master Account. Analyst is prohibited from opening or maintaining any short position in any equity index instrument while any long position in any equity index instrument remains open across any Master Account, Fast-Track Master Account, or Momentum Master Account. Any violation of these requirements will result in the termination of the applicable Account.
For same-direction and correlated-position rules, Bulenox may aggregate all Qualification Accounts, Master Accounts, Fast-Track Master Accounts, Momentum Master Accounts, and Funded Accounts, accounts under the same Rithmic User ID, accounts under the same Bulenox profile, accounts using the same payment method, IP address, device, household, entity, or other common identifier, and any accounts Bulenox reasonably determines are controlled, directed, or influenced by the same person or coordinated group.
Analyst shall not maintain opposing, hedged, offsetting, or risk-neutral positions across accounts, products, instruments, or correlated equity-index instruments for the purpose of evading risk limits, drawdown limits, consistency rules, or payout restrictions. Bulenox may treat such activity as a single combined strategy when reviewing compliance
This sequence ensures a balanced trading approach and minimizes the risk of incurring losses due to overexposure in the market. By activating multiple accounts in a structured manner, Analyst may manage their portfolios more efficiently and effectively. Only one Rithmic User ID is allowed per each Analyst. Analyst may only register one login at Bulenox.com. A Rithmic User ID will be created when subscribing to a Qualification Account. Since Analyst will have only one login on Bulenox.com, there will also be only one Rithmic User ID. All additional accounts will automatically be linked to Analyst’s Rithmic User ID. If it comes to the attention of Bulenox that Analyst has established multiple logins on Bulenox.com and possesses several Rithmic User IDs from Bulenox.com, Bulenox reserves the right, at its sole discretion, to terminate the associated Rithmic User IDs and suspend Analyst’s profile. Any fees or funds previously paid will not be subject to refund upon such termination.
This provision serves to maintain the integrity of the trading environment and to deter misuse of a Trading Platform. Violation of these terms may lead to immediate enforcement of the above stated actions without prior notice.
15. STATUS OF INDEPENDENT CONTRACTOR
Bulenox’s relationship with Analyst shall solely be that of an independent contractor. Analyst shall not be deemed to be an employee of Bulenox. Analyst shall be responsible for paying any and all applicable federal, state, local, and foreign taxes.
Prior to receiving any payouts, Analyst shall complete and submit the applicable tax form based on citizenship or tax residency status. U.S. citizens and other U.S. persons shall submit Form W-9. Non-U.S. citizens shall submit Form W-8BEN.
For U.S. citizens and other U.S. persons, Form 1099-NEC (Nonemployee Compensation) will be emailed to Analyst by Bulenox. For non-U.S. citizens, Bulenox may provide a payout certificate or similar record of payments upon request.
16. BUSINESS REGISTRATION (U.S. SINGLE-MEMBER LLC)
Bulenox LLC permits registration as a business entity solely for United States single-member limited liability companies (LLCs). The sole member and owner of the LLC must be an individual who is a resident of the United States. Business registration is available only to Analyst who has not received any Reward from Bulenox LLC in the past.
When executing the Master Account Agreement, Analyst shall provide the legal name of the company and its registered business address. When submitting Withdrawal Forms, the Analyst shall, in addition to all other required documentation, provide (i) the Articles of Organization, duly signed and, where applicable, bearing the appropriate official seal, and (ii) the Operating Agreement.
To complete the business registration, Analyst shall re-execute the applicable Master Account Agreement(s) on behalf of the company. The Agreement shall be entered into between the company and Bulenox LLC, and Analyst shall indicate both their personal name and the legal name of the company in the signature section of the Agreement.
The transition from an individual profile to a company profile may be completed only once. Upon such transition, all existing and future Master Accounts associated with Analyst shall be linked to the registered company.
17. AGREEMENT TERMINATION
Upon Analyst’s voluntary request to terminate this Agreement, all active Accounts associated with Analyst, including but not limited to any Master Accounts, shall be terminated concurrently with the termination of this Agreement. Analyst’s Bulenox Profile shall thereafter be archived, resulting in the deactivation of access to all associated Accounts and services.
Provided that Analyst is not in violation of any provision of this Agreement, Analyst shall be entitled to receive twenty percent (20%) of the net Safety Threshold Reserves for Accounts traded for up to forty-five (45) active trading days, fifty percent (50%) of the net Safety Threshold Reserves for Accounts traded for forty-six (46) to one hundred (100) active trading days, and eighty percent (80%) of the net Safety Threshold Reserves for Accounts traded for more than one hundred (100) active trading days.
After one hundred forty (140) active trading days, Analyst may terminate any Master Account(s) under this Agreement. Provided that Analyst is not in breach of any term of this Agreement, Analyst shall be entitled to receive a sum equivalent to one hundred percent (100%) of the net Safety Threshold Reserves held, subject to the provisions of this Agreement and Exhibit A attached hereto.
Any distribution of Safety Threshold Reserves pursuant to this Section shall remain subject to Bulenox’s verification procedures and Analyst’s continued compliance with all terms, conditions, and requirements of this Agreement.
Bulenox may terminate this Agreement, upon the occurrence of one or more of the following events:
If Analyst violates any of the terms of this Agreement, Bulenox may immediately terminate this Agreement by notifying Analyst in writing.
Bulenox may immediately terminate this Agreement upon written notice to Analyst in the event that Bulenox and/or Analyst becomes subject to any change in a statute, law, rule, regulation, policy, or other official pronouncement of any state or federal government entity, which would prohibit Bulenox and/or Analyst from continuing the business described in this Agreement.
If Analyst knowingly commits fraud. If Analyst knowingly defrauds Bulenox, Analyst shall pay to Bulenox or the defrauded party as damages an amount equal to the losses sustained as a result of the fraud. In the event of termination due to intentional fraud by Analyst, Bulenox may cease all payments of compensation due to Analyst immediately, without notice.
Breach of Bulenox’s guidelines and procedures. Bulenox may immediately terminate this Agreement upon written notice to Analyst in the event that Analyst materially violates any of the respective guidelines and procedures of Bulenox relating to the performance of Analyst.
Bulenox may immediately terminate this Agreement upon written notice to Analyst, in the event that Analyst violates any term of this Agreement.
Any scheme or tactic perceived as manipulative, designed to artificially inflate profits for withdrawal in either single or multiple accounts, is subject to immediate termination at Bulenox's discretion.
18. CONFIDENTIALITY
Analyst is strictly prohibited from disclosing Bulenox’s non-public personal financial information. Analyst shall keep all information strictly confidential and comply with any federal and state regulations. Financial information includes, but is not limited to, Analyst’s name, address, personal information, Tax ID, credit or debit card information, bank information, account name and number, account data and details, FCM, IB, order history, performance history, and current orders.
19. DATA AND USE
Analyst acknowledges and consents to Bulenox’s collection and aggregation of general information about Analyst and Analyst’s Master Account activity, trading patterns, preferences, and other preferences and interests. Bulenox may use and disclose such information for limited commercial purposes, and Bulenox may share or sell such aggregated general information with Bulenox’s business partners, affiliates, vendors, distributors, or other collaborators for these same purposes in accordance with applicable privacy laws and Bulenox’s Privacy Policy.
20. ARTIFICIAL INTELLIGENCE AND DATA USAGE
The Analyst acknowledges and agrees that certain Permitted Trading Platforms and Permitted Trading Tools under this Agreement may incorporate artificial intelligence (“AI”) or machine learning functionalities. The Analyst shall not employ any AI-driven trading systems, algorithms, or automated tools unless expressly included in the Account Rules or otherwise permitted by Bulenox in writing. The Analyst shall not attempt to modify, reverse-engineer, or otherwise manipulate any AI functionality within Permitted Trading Platforms or Permitted Trading Tools.
Any unauthorized use of AI or other automated trading systems under this Section 20 shall constitute a material breach of this Agreement and may result in immediate suspension or termination of Analyst’s Master Account without refund.
21. REGULATORY COMPLIANCE
21.1 CFTC/NFA Compliance
Analyst acknowledges and agrees that Bulenox exclusively offers a proprietary trading account in a simulated environment for simulation and evaluation purposes only. Bulenox does not solicit, accept, or manage customer funds, nor does it provide personalized trading advice, investment management, or any services that would require registration as a Commodity Pool Operator (“CPO”), Commodity Trading Advisor (“CTA”) or Futures Commission Merchant (“FCM”) under the Commodity Exchange Act.
Analyst further acknowledges that Bulenox is not registered with the Commodity Futures Trading Commission (“CFTC”) or the National Futures Association (“NFA”) and does not hold itself out as providing regulated advisory or brokerage services. All trading decisions are made exclusively by the Analyst, and Bulenox assumes no fiduciary duty, obligation, or responsibility for the simulated trading outcome. Analyst is responsible for ensuring compliance with all applicable laws, rules, and regulations governing their trading activities.
21.2 Prohibited Conduct
Analyst shall not, under any circumstances, engage in any activity that violates applicable laws, regulations, exchange rules, or ethical standards, including but not limited to:
Market manipulation;
Fraudulent or deceptive trading practices;
Insider trading;
Prohibited trading strategies, such as unauthorized cross-market trading or wash sales, spoofing, layering, or any other prohibited practices under CFTC and NFA rules;
Violation of Commodity Exchange Act, CFTC Regulations, NFA rules, and any applicable exchange or market conduct standards; and
Misuse of Permitted Trading Platform and Permitted Trading Tools.