OneChronos FX User Manual

Introduction

This User Manual (as amended from time to time, this “User Manual”) supplements and forms part of each Subscriber’s (as defined below) duly executed OneChronos FX Subscriber Agreement between that Subscriber and OneChronos Markets FX LLC, a subsidiary of OCX Group Inc. (“OneChronos FX” or “we”) (each such agreement a “Subscriber Agreement”; capitalized terms used in this User Manual but not defined in this User Manual shall have the meanings ascribed to them in the Subscriber Agreement). In the event of any inconsistency or conflict between this User Manual and a Subscriber Agreement, the Subscriber Agreement shall govern and control.

This User Manual provides information on the operation of the Platform and sets out terms applicable to a Subscriber’s execution of Spot FX transactions on the Platform or Subscriber’s other use of Services offered by OneChronos FX.

OneChronos FX is not registered as a swap execution facility, multilateral trading facility, or organized trading facility. Each Subscriber is responsible for ensuring its own regulatory compliance, including with respect to applicable laws, including anti-money laundering laws, reporting, clearing, and position limits.

This User Manual may be amended from time to time upon notice to Subscribers, which notice may be provided by posting it on the OneChronos website together with the revised User Manual. The amended User Manual will be effective on the date specified in such notice and supersedes each prior version as of such effective date with respect to use of the Platform or Services on and after the effective date.

This User Manual does not constitute, and shall not be construed as, a representation, warranty, or commitment by OneChronos FX regarding any Subscriber’s trading outcomes, execution results, pricing, liquidity, or profitability.

OneChronos FX may interpret, administer, and apply this User Manual in its sole discretion in connection with the operation of the Platform.

Certain Definitions

For purposes of this User Manual, the following terms have the following meanings:

Participation on OneChronos FX

Subscribers must adhere to this User Manual in respect of their use of the Platform or Services, as well as the Subscriber’s executed Subscriber Agreement. Apart from any rights or remedies OneChronos FX may have under the Subscriber Agreement or otherwise, OneChronos may suspend or restrict a Subscriber’s access to the Platform or Services if the Subscriber fails to comply with its Subscriber Agreement or this User Manual.

Only Subscribers may directly enter orders on the Platform. A Subscriber must be an “eligible contract participant” as defined under the CEA and the rules, regulations or interpretations of the CFTC. In addition, each Subscriber that permits any Client to indirectly access the Platform to trade in Subscriber’s name must assure that the Client is and remains at all times an eligible contract participant.

OneChronos FX operates the Platform as a neutral technology provider and does not act as an agent, fiduciary, investment advisor, or representative of any Subscriber or Client in connection with trading decisions or execution strategy. OneChronos FX does not provide investment advice, trading advice, or recommendations of any kind.

All orders submitted to the Platform are submitted at the sole discretion and responsibility of the Subscriber. Subscribers are solely responsible for determining whether any order, execution strategy, or transaction is appropriate for them and for ensuring compliance with all applicable legal and regulatory requirements.

Any descriptions of the Platform’s matching, optimization, or pricing processes are provided for informational purposes only and do not create any duty or obligation on the part of OneChronos FX.

Eligibility to access the Platform does not imply that any Subscriber or Client will be able to transact, access liquidity, or achieve any particular trading outcome.

Prime Broker Arrangements

The Platform employs two types of prime brokers, a Central Prime Broker and a Subscriber Prime Broker (each, a “Prime Broker”), and each of these prime broker arrangements is more fully described below.

OneChronos FX employs a “central prime” model whereby a single firm is designated by OneChronos FX as the Central Prime Broker. The Central Prime Broker has represented to OneChronos FX that the Central Prime Broker is an eligible contract participant.

In addition to the Central Prime Broker, a Subscriber or other prime broker approved by the Platform may also act as a Subscriber Prime Broker for other Subscribers, in each case if authorized by OneChronos FX in its sole discretion. As a condition to become and remain a Subscriber Prime Broker, among other things, each Subscriber Prime Broker must have an acceptable arrangement in place with the Central Prime Broker whereby the Central Prime Broker is the Prime Broker on the Platform for it in its capacity as a Subscriber Prime Broker for other Subscribers, as confirmed to OneChronos FX by the Central Prime Broker. A Subscriber, in its capacity as a Subscriber Prime Broker will settle transactions of an Authorized Subscriber executed on the Platform as the result of give ups on executions as more fully set forth in Section 4.4 of this User Manual (Trade and Settlement Workflow). A Subscriber’s role as a Subscriber Prime Broker does not limit Subscriber’s ability to transmit orders to be executed in its own name on the Platform.

To transmit orders to the Platform, a Subscriber must have an appropriate prime brokerage arrangement to settle trades on the Platform with either (i) the Central Prime Broker directly, or (ii) a Subscriber Prime Broker where the Subscriber Prime Broker in turn has an arrangement directly with the Central Prime Broker. A Subscriber may have multiple prime broker relationships on the Platform, in that Subscriber may have prime brokerage arrangements in place with the Central Prime Broker and/or by one or more Subscriber Prime Brokers. A Subscriber, though, may only use a single prime broker arrangement per session as prescribed in the Port Session Configuration form.

If a Subscriber has properly engaged a Prime Broker, the Prime Broker may permit a Client which has prime broker arrangement with the Subscriber to access the Platform indirectly through Subscriber’s connections to the Platform, whereby any transactions on the Platform resulting from Client’s indirect access are executed in the name of the Subscriber as principal and settled with Subscriber’s Prime Broker. The execution of any offsetting leg transaction between Subscriber and Client is solely a matter between Subscriber and Client that occurs outside the Platform and any error or dispute or failure to conclude such transaction between the Subscriber and Client does not affect Subscriber’s related transaction executed on the Platform, which remains a binding transaction. Additionally, with respect to any Client, the Subscriber is responsible for and acknowledges that the Platform is relying on Subscriber’s assurance that it will at all times (i) ensure that the Client complies with the applicable terms of the Subscriber Agreement and this User Manual; and (ii) maintain an anti-money laundering (AML) program reasonably designed to detect and deter money laundering activities, as well as a customer identification program, each in accordance with applicable laws and regulations. This includes, without limitation, properly verifying that at all times each Client is not itself, and is not acting on behalf of any person or entity that is: (x) owned 50% or more, directly or indirectly, by any individual or entity identified on the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) Specially Designated Nationals and Blocked Persons List; (y) located in, or owned or controlled by the government of, a country or territory subject to comprehensive OFAC-administered economic sanctions; or (z) otherwise subject to restrictions imposed by any governmental authority with jurisdiction to administer economic sanctions or blocking measures over the Client. Subscribers shall cooperate with any reasonable inquiries by OneChronos FX relating to their controls and compliance programs related to the Platform and their Clients.

The series of prime broker arrangements described above contribute to maintaining pre-trade and post-trade anonymity and facilitate settlement of transactions occurring on the Platform. OneChronos FX requires that all Prime Brokers on the Platform, including the Central Prime, maintain and enforce appropriate anti-money laundering policies and procedures, including customer identification and customer due diligence procedures, reasonably designed to detect and deter money laundering and other illicit activity, in accordance with applicable law.

The Central Prime Broker may impose credit, position, or other limits (“Credit Limits”) on any Subscriber Prime Broker or on any Subscriber for which it has agreed to act as Prime Broker. A Subscriber Prime Broker may likewise impose its own Credit Limits on any Subscriber for which it acts as Prime Broker and, where applicable, on the Central Prime Broker.

Where a Subscriber trades with the Central Prime Broker pursuant to a direct credit arrangement, reciprocal Credit Limits may apply between those parties. In such cases, the Platform will enforce the applicable Credit Limits made available to it for purposes of transaction eligibility, which may reflect limits established by one or both counterparties.

All orders submitted to the Platform, whether directly by a Subscriber or indirectly by a Subscriber’s Client, are subject to credit intermediation by the relevant Prime Broker(s). The Platform relies on and enforces Credit Limits properly submitted to it by the applicable Prime Broker(s) during its matching process. Execution of a transaction does not constitute a representation that such Credit Limits are sufficient for settlement or that either counterparty will accept or perform the transaction.

The Central Prime Broker may conduct its own independent verification of compliance with its Credit Limits (and other technical requirements) outside the verification conducted by the Platform. In the event the Central Prime Broker rejects a transaction matched by the Platform, transactions matched during the relevant auction for the affected currency pair may be unwound in accordance with Platform procedures.

When a Subscriber uses OneChronos in conjunction with any other execution strategy, a Subscriber is responsible for ensuring that it does not disclose confidential trading information relating to executions on OneChronos to external parties, except as necessary to effect the execution or settlement of a transaction.

Trading Operations

During Trading Hours, the Platform operates periodic auctions deliberately initiated by the matching engine at randomized times at a frequency of approximately 10-15 auctions per second.

The Platform utilizes standard spot settlement dates and precision per pair and may change its set of supported instruments from time to time. This may include other settlement dates or pricing references. The current list of instruments and allowed pricing increments will be available on our website and updated from time to time.

Trading Hours

On each Trading Day, Trading Hours will be between the hours of 08:00 to 22:00 Coordinated Universal Time (UTC), corresponding to 9:00am London local time (whether GMT or BST) through 5:00pm U.S. Eastern Time (whether EST or EDT), accounting for daylight saving time changes, Monday to Friday. The Platform is closed on Christmas Day and New Year’s Day.

Matching Process

Rather than matching orders continuously as they arrive at the matching engine (as with a continuous limit order book) the Platform periodically holds auctions designed to seek an optimal matching between buyers and sellers across all eligible orders. These auctions are multi-lateral in that one or more buyers can be matched with one or more sellers in the same currency pair.

The Matching Process is algorithmic and mechanical in nature and does not involve the exercise of discretion by OneChronos FX with respect to individual orders or Subscribers. Participation in an auction does not guarantee that any order will be executed, partially executed, or executed at any particular price.

In a fully non-displayed environment, Subscribers can enter Limit Orders, Midpoint Peg Orders, Primary Peg Orders and Market Peg Orders (all peg types supported with or without an offset) in a single currency pair. The various peg types are defined as follows:

• Midpoint Peg - Execute at a price equal to or more favorable than the midpoint of the prevailing bid and offer.
• Primary Peg - Execute at a price equal to or more favorable than the prevailing bid in the case of a buy order or offer in the case of a sell order.
• Market Peg - Execute at a price equal to or more favorable than the prevailing offer in the case of a buy order or the bid in the case of a sell order.

Peg Orders will leverage an independent third-party market data source. The price leveraged for the peg will be based on the most recent relevant price available for that currency at or most recently prior to the auction call time.

OneChronos FX employs an optimization process to evaluate eligible orders submitted prior to an Auction Cutoff Time and to determine feasible matches, subject to applicable constraints, including Credit Limits, credit availability, order eligibility, timing, and system rules. The optimization process evaluates potential solutions and identifies matches that seek to maximize total Aggregate Price Improvement across eligible orders considered in a given auction.

“Aggregate Price Improvement” refers to Price Improvement multiplied by the order quantity potentially filled for all orders across multiple Subscribers and across all pairs in each auction.

Aggregate Price Improvement is a mathematical objective used by the optimization process and does not represent a guarantee of execution, execution price, or economic benefit to any Subscriber or Client.

The Platform operates without “last look.” Orders that are eligible for participation in an auction are firm and binding upon execution and may not be rejected due to subsequent market movement or price evaluation.

Contact FXinfo@onechronos.com for further information or to initiate connectivity discussions.

Order Types and Entry

All orders entered on the Platform are considered firm and are sent via standard FIX (4.2) protocol. New orders receive an acknowledgement from the Platform via an execution report (as do orders that have been canceled and replaced).

The Platform accepts two standard order types — Limit Orders and Peg Orders (with or without an offset). In the case of a Peg Order (Midpoint, Primary, or Market), a peg price is computed using the independent third-party market data source, as is described in the Matching Process Section. A limit price can also be included on pegged orders. For Peg Orders submitted with an offset, the offset is specified as an absolute price difference and applied directly to the reference price.

The effective price of a Midpoint Peg Order reflects the application of any specified offset to the applicable reference price. Sub-tick prices may be accepted where supported by the Platform. Orders with effective prices that fall outside applicable market quality or risk thresholds may be adjusted, constrained, or rendered ineligible for execution in accordance with Platform rules.

Certain order types reference prices derived from third-party market data sources. OneChronos FX does not control, verify, or guarantee the accuracy, completeness, timeliness, or availability of any market data provided by third party sources.

All limit prices and offsets must abide by the supported pricing precision as defined in the Symbology section on our website. Limit prices/offsets that exceed our supported precision are deemed impermissible and will be rejected. Orders submitted with fractional or non-integer quantities will also be rejected.

For a Peg Order submitted with a limit price, the Effective Price used by the Platform in each auction is the less aggressive of (i) the applicable reference price specified by the peg instruction (as adjusted by any specified offset) and (ii) the submitted limit price.

The limit price acts as a protective constraint and does not cause the order to execute at a price worse than the reference price. If the reference price moves beyond the submitted limit price, the order continues to express interest at the limit price.

The Effective Price is used by the Platform to evaluate execution eligibility and price improvement calculations for an order. All orders must include an amount and price specified using the standard currency within the currency pair. Terms trading is not supported at this time.

Cancellation and modification requests are subject to Platform and auction cut-off times and processing rules. Cancellation or modification requests received after the applicable Auction Cutoff Time may not take effect until a subsequent auction cycle, and the order may participate in the current auction notwithstanding such a request.

OneChronos FX shall not be liable for any losses or damages arising from market data inaccuracies, rounding conventions, or differences between displayed and executed prices.

OneChronos FX may introduce, modify, suspend, or discontinue order types or order features at any time. OneChronos FX is not obligated to support any order type or instruction indefinitely.

Orders may rest on the Platform using a Time-in-Force of Day, Good ’Til Date (“GTD”), or Good ’Til Cancelled (“GTC”). All orders remaining open at the end of a trading session are automatically cancelled by the Platform, regardless of Time-in-Force designation. A GTD order may specify an expiration time beyond the end of the trading session; however, such order will expire at the earlier of (i) its specified expiration time or (ii) the end of the trading session.

In the event of a partial fill for an order persisting on the Platform, the residual quantity will automatically be queued to participate in subsequent auction cycles until cancelled, fully filled, or expired in accordance with its Time-in-Force instruction.

Alternatively, orders may be designated to participate in a single auction using a Time-in-Force instruction of Immediate or Cancel (“IOC”) or Fill or Kill (“FOK”). In such cases, any unexecuted quantity will be cancelled back to the Subscriber at the conclusion of the relevant auction cycle.

While unexecuted orders or unexecuted portions of orders can be canceled outside of an auction optimization sequence, once an execution has occurred, the executed portion of the order cannot be canceled.

Further information relating to connectivity, order instructions and more related messaging instructions are available in the FIX specification available on the Platform’s website available at https://www.onechronos.com/documentation/fix/fix-42/fx/.

Trade and Settlement Workflow

To preserve true all-to-all functionality and facilitate anonymity on both a pre and post trade basis, the Platform employs a central prime clearing model, using a single firm as the Central Prime Broker, as explained in Section 3 of this User Manual. A Subscriber must have an appropriate credit arrangement to settle trades on the Platform with either (i) the Central Prime Broker directly, or (ii) a Subscriber Prime Broker where the Subscriber Prime Broker in turn has an arrangement directly with the Central Prime Broker.

Each session must contain the designation of the Prime Broker to which any resulting transaction will be given up or the Platform will reject the order. If a Subscriber has client relationships with multiple Subscriber Prime Brokers, the Subscriber will need to establish a dedicated session within the Platform for each relationship.

Execution Reports; Risk Transfer: Finality

A transaction is executed when it is confirmed by the Platform through the issuance of an execution report. Upon execution, the transaction is final and binding on the counterparties, regardless of whether either counterparty, or any intermediary acting on its behalf, acknowledges receipt of the execution report. The terms of a transaction as set forth in the execution report issued by the Platform shall constitute conclusive evidence of the transaction’s execution under such terms for purposes of Platform operations.

A Subscriber Prime Broker, Subscriber or Client may not dispute the terms of a transaction reflected in an execution report, except in accordance with the Off-Market Policy and Error Policy set forth in this User Manual; provided that any such dispute shall not relieve Subscriber of its obligation to perform. Nothing in this section obligates OneChronos FX to modify, cancel, or unwind any transaction whether or not disputed or in connection with a Bona Fide Error.

OneChronos FX is not a counterparty to transactions executed on the Platform and does not assume responsibility for the performance or settlement of such transactions. OneChronos FX shall not be liable for any losses arising from a failure by counterparties to agree on the resolution of a disputed transaction.

Execution on the Platform does not constitute a guarantee of settlement, novation, or performance by any Prime Broker or counterparty.

Credit Limits; Breaches

Execution of a transaction on the Platform reflects enforcement of Credit Limits as configured and available to the Platform at the time of execution. OneChronos FX does not guarantee settlement or acceptance of a transaction by any Prime Broker, and any actions taken by the Platform in response to a Prime Broker’s rejection or withdrawal of credit are operational in nature and do not constitute an admission of error.

For transactions where a Subscriber utilizes a Subscriber Prime Broker, the Subscriber Prime Broker is deemed to accept give up of the transaction and its inter-positioning as the counterparty to the Subscriber on the transaction on the terms set forth on the execution report sent to the Subscriber and as the counterparty to the Central Prime Broker on the opposite transaction with the Central Prime Broker on the terms set forth on the relevant execution report for such transaction.

Each Subscriber utilizing the services of the Central Prime Broker acknowledges that the Central Prime Broker may impose Credit Limits on it and may adjust those Credit Limits from time to time and that it is responsible for staying informed of the Credit Limits imposed by the Central Prime Broker on it.

A Subscriber Prime Broker is responsible for establishing and maintaining credit limits (the “Submitted Credit Limits”) for each of its Subscriber clients and for monitoring its Subscriber clients and updating their Submitted Credit Limits as appropriate. A Subscriber Prime Broker must establish Submitted Credit Limits that in the aggregate do not exceed the Submitted Credit Limits imposed on it by the Central Prime Broker, and also account for the Subscriber Prime Broker’s potential level of trading on the Platform in its own name.

A Prime Broker must enter its Credit Limits and any changes to Credit Limits directly on the Platform in the manner instructed by OneChronos FX, which become effective only once properly transmitted and accepted by the Platform in accordance with OneChronos FX’s technical procedures. OneChronos shall not be responsible for any losses to a Subscriber or to any other person arising from such Prime Broker’s failure to establish, maintain, update or monitor a Subscriber’s Credit Limits. Orders sent to the Platform by a Subscriber Prime Broker’s Subscriber client that result in transactions are deemed binding obligations on the Subscriber Prime Broker as the give up party to the transactions.

OneChronos FX relies exclusively on Credit Limits and related information submitted by Prime Brokers in accordance with Platform procedures. OneChronos FX does not independently verify the economic accuracy or sufficiency of any Credit Limits and shall not be responsible for any losses resulting from stale, incorrect, or misconfigured Credit Limits or a Prime Broker’s rejection of a transaction matched by the Platform.

Platform Operations

The OneChronos FX auction lifecycle consists of the following five steps, which occur in sequence and are repeated throughout Trading Hours. Note that at the current time, OneChronos FX maintains a single PoP.

1. Initialization Time: an Auction Cutoff Time is randomly chosen following the completion of the prior auction lifecycle, drawn at random within a range of 20 milliseconds to 120 milliseconds following completion from the previous auction;
2. Auction Network Buffer: a period of time elapses to allow sufficient time for orders and market data to arrive. The length of the Auction Network Buffer can vary based on expected transmission times, but would typically be on the order of tens of milliseconds or less;
3. Match Optimization Process: the Platform runs its trade matching process, which determines prices and volume allocations across all currency pairs and Subscribers;
4. Post Auction Network Buffer: Upon completion of the Match Optimization Process, the matching engine broadcasts auction results to the Platform’s Point of Presence (“PoP”). The PoP waits until a predetermined time (which always precedes the following auction’s Match Optimization period) to distribute trade give-ups, thereby providing synchronized dissemination of such data externally. As with the Auction Network Buffer, the length of the Post Auction Network Buffer can vary based on expected transmission times but is typically on the order of tens of milliseconds or less; and
5. Data Dissemination: At the conclusion of the Post Auction Network Buffer period, the PoP communicates auction results in the form of trade give-ups to external parties, including Subscribers (including Subscribers receiving fills as a Subscriber Prime Broker) and the Central Prime Broker.

The Platform allows Subscribers to cancel and replace existing orders during the Order Collection Window. Cancellation requests received and timestamped before the Auction Cutoff Time (i.e. during the Initialization Time described above) have immediate effect. Cancellation requests received after the Auction Cutoff Time but before the completion of the Match Optimization Process do not have effect until the following auction cycle (and therefore the order may still participate in the auction notwithstanding the cancellation request). If a cancel request for an existing order is received while participating in an auction, the Subscriber will receive a pending cancel notification in response. Any residuals not executed within that auction will be canceled back to the Subscriber once the auction is completed.

The Platform supports Time-in-force instructions of: Day, Immediate or Cancel, Fill or Kill, Good ‘Til Date (with an expire time not to exceed the end of the current trading session), and Good ‘Til Cancel (which will persist until a Subscriber cancels or OneChronos ends the trading session for the day).

Auction timing, frequency, and sequencing are determined by the Platform and may vary due to system conditions, market conditions, or operational considerations.

Access and Connectivity

Only Subscribers can access the Platform. A Subscriber must execute a Subscriber Agreement and, among other things, must represent and warrant that it has the necessary right, power and authority to execute and deliver the Subscriber Agreement and to perform its obligations thereunder. Subscribers must also go through the Platform’s onboarding and testing procedures to ensure it is ready to trade on the Platform.

OneChronos FX allows Subscribers to connect directly to the Platform via cross-connect or via extranet. The currently maintained PoP is located at Equinix NY3. Connectivity options include 1 gigabit or 10 gigabit single-mode optical fiber (SMF). Orders may only be submitted electronically. The Platform does not accept telephone orders.

For specific details relating to connectivity, please see our FIX specification. Please contact FXinfo@onechronos.com or fxmarketops@onechronos.com for further information or to initiate connectivity discussions.

Market Quality and Risk Controls

Before each auction, the Platform carries out a series of pre-match market quality and risk checks. These consist of verifying that Subscriber configured risk checks pass, and flagging “off-market” orders (see following section) so as not to unduly influence the auction. For Subscriber controlled risk checks, the following parameters are configurable within bounds that have been established by OneChronos FX:

• total notional value maximums per order
• currency restrictions
• self-trade prevention controls at the Subscriber and/or FIX session level
• The Platform may also enforce notional value constraints according to maximums put in place by our Central Prime Broker, and/or a Subscriber’s Prime Broker. As an additional risk control, orders with Subscriber-supplied prices 3% or more aggressive than the prevailing best bid or offer are not eligible for participation but will persist with the Platform until such a time that the supplied price is within the 3% threshold or the order is cancelled (either by Platform or by Subscriber). Subscribers are able to configure this setting to be more restrictive than the Platform setting of 3%. Orders with prices that fall outside applicable market quality thresholds may be constrained, adjusted, or rendered ineligible for participation in an auction in accordance with Platform rules.

If a currency pair experiences an intraday price movement exceeding 3.5% measured from the first midpoint price available post Platform open, OneChronos FX reserves the right to halt trading in that pair. Trading may resume at our sole discretion, based on our assessment of market conditions and risk factors.

Off-Market Policy

Off-Market orders are identified as orders whose limit prices are substantially away from what OneChronos FX considers to be the prevailing market at the time of auction cut-off. To identify these orders, a comparison is made between the Subscriber’s limit price and the prevailing market price as determined by OneChronos FX in its discretion. Should an order’s limit price exceed a threshold, the order may be left open, but capped at an effective price within the Platform’s acceptable threshold price for the currency pair. This mechanism is designed to prevent such orders from disproportionately influencing execution price determined by the auction.

A Subscriber that believes an execution occurred as the result of an off-market price or a pricing error must notify OneChronos FX within thirty (30) minutes of execution as specified below.

In connection with any review of a potential off-market execution, OneChronos FX may, in its discretion, contact one or more counterparties to the transaction and may review information it deems appropriate to assess prevailing market conditions at the time of execution. OneChronos FX may share relevant information with affected counterparties as part of its review process.

Possible outcomes of a review include, without limitation, the execution being upheld as executed, modification of one or more terms of the execution, or voiding of the execution. Notices must be submitted by electronic mail to (FXmarketops@onechronos.com) and must include, at a minimum:

• the time of order entry
• the time of execution
• the applicable currency pair
• the notional amount
• the execution price
• the side (buy or sell)
• a factual basis for believing the execution was off-market or erroneous

Failure to provide timely and complete notice may result in the execution being deemed final. Requests received after the applicable time period may be reviewed in OneChronos FX’s sole discretion and OneChronos FX reserves the right to decline to review any request that does not comply with the notification requirements set forth above.

To further reduce the possibility for Off-Market trades to occur, OneChronos FX may determine not to allow an auction to occur if the clearing price of the auction would be calculated to be outside of the threshold OneChronos FX deems to be consistent with the prevailing market conditions.

OneChronos FX reserves the right, in its discretion, to review any transaction executed on the Platform, including any transaction executed at a price within the Platform’s acceptable threshold. Furthermore, OneChronos FX reserves the right, in its discretion, to decline to review any transaction executed on the Platform.

Any determination by OneChronos FX with respect to an off-market or error execution shall be final for purposes of Platform operations. Nothing in this section limits the application of applicable regulatory rules or the authority of any regulator or self-regulatory organization.

OneChronos FX shall not be liable for any losses arising from an execution that is upheld, modified, or voided pursuant to this Section 5.3.

Technology, Security and Resiliency

OneChronos FX uses high precision time synchronization and timestamps orders on the network level as they are received. Timestamped data is transmitted to the Platform’s central matching engine. In an effort to promote fairness, the timestamp on each order rather than its arrival time at the matching engine is used to determine that order’s eligibility for an auction.

The matching engine is designed to scale even as order volume and order complexity grows.

There is no guarantee that the Services provided by OneChronos FX, including the Platform, will meet the Subscriber’s requirements, be error free, or operate without interruption or delay. Subscriber acknowledges that all or portions of the Services may be unavailable from time to time. Subscriber agrees to maintain arrangements with other market centers (such as other broker-dealer operated alternative trading systems) sufficient for Subscriber to conduct its business in the event the Services are unavailable.

Acceptable Use

Subscribers agree not, and not to allow third parties (including any Client or Authorized Person) to use the Platform or related services:

• to violate, or encourage the violation of, the legal rights of others;
• to engage in, promote, or encourage fraudulent, manipulative or other illegal activity;
• for any unlawful, invasive, infringing, defamatory, or fraudulent purpose;
• to interfere with the use of the Platform, or the equipment used to provide the Services, by customers, or other Authorized Persons; or
• to disable, interfere with, or circumvent any aspect of the Services.

Error Policy

The responsibility of order submission accuracy lies with the Subscriber. OneChronos FX does not generally cancel or modify any transaction executed on the Platform on the basis that the order was submitted by Subscriber (including indirectly by a Client of Subscriber) in error or was submitted with terms that were inaccurate.

A Subscriber that believes an execution constitutes a Bona Fide Error Trade must notify OneChronos FX promptly and in accordance with procedures communicated by OneChronos FX from time to time; provided that nothing herein shall relieve such Subscriber from its obligations to perform or obligate OneChronos FX to modify, cancel, or unwind any transaction, including in the event of a Bona Fide Error. In the event of a Platform level execution error as a result of, for example, a system failure or error in market data required for pegged orders, all relevant orders on OneChronos FX will either be canceled back to the Subscriber or entered into a suspended state. OneChronos FX will also stop trading in all or a subset of currency pairs affected.

In the case of a client disconnect, OneChronos FX supports the ability to configure port setting: cancel on disconnect.

OneChronos FX or the Central Prime Broker may suspend trading temporarily if certain risk or error conditions are detected including but not limited to those that would materially impact OneChronos FX’s ability to match trades (such as loss or material degradation of communication between the matching engine and the PoP).

In the event of real-time trading issues or trade correction requests, OneChronos FX can be reached via phone (+1 779-249-7911) or email (FXmarketops@onechronos.com).

Market Conduct

Subscribers shall submit orders with a bona fide intent to trade and shall not engage in conduct that is manipulative, deceptive, or disruptive to the orderly operation of the Platform.

Subscribers are responsible for maintaining appropriate internal systems and controls to prevent erroneous or abusive order submissions and for cooperating with any reasonable inquiries by OneChronos FX relating to Platform activity.

Privacy Policy

When you visit websites operated by OneChronos, OCX Group, or any of their affiliates or subsidiaries (collectively, “OneChronos”), you consent to the collection, use, disclosure, and processing of your personal data as described in our Privacy Policy. Our Privacy Policy may be updated from time to time. The current version is available here.

Our Privacy Policy explains how OneChronos handles personal data in connection with the use of our websites and services, including the OneChronos FX trading platform, and is designed to comply with applicable data protection laws, including the European Union’s General Data Protection Regulation (GDPR), the UK GDPR, and other relevant international privacy regulations.

Categories of Data Collected.

We may collect and process various types of personal data, including but not limited to identity information (e.g., name, business affiliation), contact details (e.g., email address), technical and usage data (e.g., IP address, session logs), and information relating to trade execution and platform usage.

Purpose and Legal Basis for Processing.

We process your personal data where necessary for the performance of our contractual obligations to you (e.g., providing access to the Platform), for compliance with our legal obligations (e.g., regulatory reporting), and for our legitimate interests (e.g., security, fraud prevention, and service improvement). In limited circumstances, we may rely on your consent, such as for marketing or the use of certain cookies.

Data Sharing and Transfers.

Personal data may be shared with service providers, affiliates, and regulatory authorities, as needed. Where data is transferred outside of the European Economic Area (EEA) or other jurisdictions with equivalent protections, we ensure adequate safeguards are in place in accordance with applicable laws, including the use of Standard Contractual Clauses where necessary.

Your Rights.

If you are located in the EU, UK, or other jurisdictions with similar legal frameworks, you may have rights in relation to your personal data, including the right to:

• Access your data
• Request correction or deletion
• Restrict or object to processing
• Data portability (where applicable)
• Lodge a complaint with a supervisory authority

You may exercise these rights by contacting us at info@onechronos.com.

Cookies and Tracking Technologies.

We may use cookies and similar tracking technologies on our websites for essential operations, analytics, and user experience enhancement. Details regarding our use of such technologies, and how to manage your preferences, can be found in our Cookie Policy. Our Cookie Policy may be updated from time to time. The current version is available here.

For questions regarding our data privacy practices, you may contact us at info@onechronos.com.

Governing Law and Dispute Resolution.

For clarity, the governing law, jurisdiction, and dispute resolution terms applicable to a Subscriber’s use of the Platform are set forth in the Subscriber Agreement and incorporated herein by reference.