LEGAL DISCLAIMER & IMPORTANT DISCLOSURES

Simulated Trading Environment

All trading accounts provided through this website operate exclusively within a simulated environment utilizing virtual capital. No actual trades are executed on live financial markets. The services offered by Royal Flow - FZCO and its affiliated entities are designed solely for educational purposes, skill assessment, and the evaluation of trading proficiency and risk management capabilities.

You hereby acknowledge that any actions taken through our Services are simulated and are reflected exclusively within our internal systems. No real trading on real markets takes place as a result of your use of our Services. All funds designated for trading within the Services are purely virtual, allocated for simulated trading purposes, and cannot be used for real-world trading activities. You are not entitled to any payment of those virtual funds in real-world currency or other form.

Corporate Structure & Registered Entities

Royal Flow - FZCO

Royal Flow - FZCO (License No. 35886) is a technology and education company duly incorporated under the laws of the United Arab Emirates, with its registered office at Building A1, IFZA Business Park DDP, Dubai Silicon Oasis, Dubai, United Arab Emirates.

Royal Flow - FZCO operates the Tradelocker trading platform. The technical infrastructure, data feeds, and liquidity solutions for the platform are provided by institutional third-party providers.

Upcomers Ltd.

Upcomers Ltd. is an international business company duly incorporated under The International Business Companies Act Cap 12.14 of the revised laws of Saint Lucia on August 8, 2025, with company number 2025-00579, having its registered office at Ground Floor, The Sotheby Building, Rodney Village, Rodney Bay, Gros-Islet, Saint Lucia.

Upcomers Ltd. operates Metaquotes “MT5” trading platform. All Metaquotes trading platforms are operated exclusively by Upcomers Ltd. The technical solution and data feed for MT5 platform are powered by institutional liquidity providers.

Risk Warning — Upcomers Ltd.
Upcomers Ltd. provides access to simulated trading accounts only. Users should be aware that engagement with live trading in financial markets involves substantial risk and is not suitable for all individuals. CFDs and similar derivative instruments are complex products with speculative characteristics due to leverage and market volatility.

Website Ownership

No Investment Services

The simulated trading services accessible through this website are provided by Royal Flow - FZCO and Upcomers Ltd. (collectively, the “Company”). All content published and distributed by the Company and its related entities is intended for general informational and educational purposes only.

• The Company does not provide investment advice, portfolio management, or any form of personalized financial guidance.
• The Company does not solicit, recommend, or encourage the purchase or sale of any financial instruments, securities, funds, cryptocurrencies, or derivatives.
• The Company does not act as a broker, dealer, exchange, custodian, or financial intermediary.
• The Company does not accept or manage client deposits, nor does it facilitate live market transactions.

Nothing on this website or within our programs constitutes an offer, solicitation, or recommendation to buy or sell futures, options, CFDs, forex, stocks, cryptocurrencies, or any other financial instruments. No personnel, agents, or any other third parties acting on our behalf are authorized to provide investment advice or similar suggestions.

Participants are strongly encouraged to consult independent financial, legal, or tax advisors before engaging in any trading activity outside of this program.

Unregulated Provider

We are not a brokerage firm, nor a trading platform, and we do not accept any deposits nor allow you to conduct any real-world financial transactions. The relevant information, technical framework, and data feed for our platform are provided by our partners – institutional liquidity providers.

Royal Flow - FZCO and Upcomers Ltd. are not regulated financial institutions and do not provide services as defined under applicable securities, investment, or financial services laws. The Company does not hold any brokerage, investment advisory, or financial services licenses, and does not conduct activities that would require such licensure.

Program Fees & Payment Terms

Participation in any of our evaluation programs is entirely voluntary. All fees paid to the Company are strictly service fees for access to educational software, simulated trading environments, and evaluation services.

• Program fees are not deposits and do not represent client funds under any circumstances.
• Program fees should not be considered investments, and payment does not create any fiduciary duty, custodial relationship, or investment arrangement between participants and the Company.
• Program fees do not earn interest, returns, or profit sharing of any kind.

All program fees are applied toward the Company’s operational and administrative expenses, including but not limited to: staffing, technology infrastructure, platform development and maintenance, software licensing, risk management systems, customer support, and other business-related costs.

Program fees are non-refundable once paid, except where expressly stated in our refund policy or required by applicable law.

Educational Use Only

All content, tools, analytical features, and services provided by the Company and its affiliates through this website are intended strictly for informational and educational purposes. The content and services do not constitute investment advice, trading signals, or personal recommendations.

The simulated trading accounts provided are designed solely to evaluate users’ trading skills and risk management abilities within a controlled, risk-free environment. At no time are users required to deposit capital for investment purposes, nor do they risk their own funds. Program outcomes depend solely on individual performance and adherence to the stated rules and objectives.

As a result of the nature of the Services, you shall not be entitled to any fees or profits, nor to any other simulated financial gain generated by or otherwise resulting from the virtual trading. You shall, however, also bear no losses resulting from the virtual trading via the Services.

Hypothetical Performance Disclosure — CFTC Rule 4.41

CFTC Rule 4.41 notes that hypothetical or simulated performance has inherent limitations that do not fully equate or otherwise mirror actual trading in real markets. Unlike actual performance records:

• Simulated results do not represent real trading activity and are not executed in live market conditions.
• Simulated results may under-compensate or over-compensate for market factors such as liquidity, slippage, and execution delays.
• Simulated results are often designed with the benefit of hindsight and may not account for the financial risks associated with live trading.

No representation or warranty is being made that any account will, or is likely to, achieve profits or losses similar to those displayed, referenced, or implied on this website or within our platform. Past performance does not predict future results.

Customer Compensation & Testimonials Disclosure

All compensation figures, payout examples, and performance statistics presented for customer trading activities should be regarded as hypothetical. Such results are not indicative of, and should not be expected to replicate, performance in live trading accounts.

Testimonials do not represent the experiences of every user and shall not be considered a guarantee or even an indication of future performance. These should not be viewed as guarantees or assurances of future performance or success.

General Risk Warning

Involvement in financial markets is inherently risky; it is recommended not to risk more than one can afford to lose. Forex trading as well as trading in almost any other market with almost any other instrument involves substantial risk and is not suitable for every investor.

Even in a simulated environment, strategies tested under leveraged conditions may produce outcomes that do not reflect real-world execution or performance. Only risk capital — funds you can afford to lose — should be used or even allocated for both real-world trading and the order of our Services.

You should carefully consider your investment objectives, level of experience, risk tolerance, and financial situation before participating in any trading activity, whether simulated or live. Past performance, whether actual or simulated, is not necessarily indicative of future results.

Technology & Third-Party Providers

The technical solutions used in our Services are sourced from third-party providers. The technical infrastructure, trading platforms, data feeds, and liquidity solutions utilized in connection with our services are provided by independent third-party providers. Royal Flow - FZCO and Upcomers Ltd. are not responsible for any disruptions, inaccuracies, delays, or limitations associated with these third-party services.

Users acknowledge that the operators of all trading platforms accessible through our services are separate entities governed by their own terms, conditions, and privacy policies. The Company has no control over such third-party operators and assumes no liability for their actions or omissions.

Jurisdictional Restrictions & Service Availability

The information on this Website is not aimed at residents in any jurisdiction where its distribution or use would conflict with applicable local legal statutes.

Due to legal considerations, regulatory requirements, and risk management protocols, the Company does not offer services to residents of the following countries and regions:

• Afghanistan
• Central African Republic
• Crimea, Donetsk and Luhansk regions of Ukraine
• Cuba
• Iran
• Iraq
• Kosovo
• Libya
• Mali
• Myanmar
• North Korea
• Pakistan
• Palestine
• Russia
• Somalia
• South Sudan
• Sudan
• Syria
• Vanuatu
• Venezuela

Users are solely responsible for ensuring that their access to and use of our services complies with all applicable laws and regulations in their jurisdiction.

Limitation of Liability

Use of any of the information provided by us is at the User’s own risk. We bear no responsibility for any such use, especially outside of our simulated platform.

To the maximum extent permitted by applicable law, the Company, its directors, officers, employees, agents, and affiliates shall not be liable for any direct, indirect, incidental, special, consequential, or punitive damages arising from or related to:
• Your use of or inability to use our services, website, or platforms.
• Any reliance on information, content, or results displayed on this website.
• Any trading decisions made based on simulated results or educational content.
• Any third-party products, services, or platforms accessed in connection with our services.
• Any technical failures, interruptions, or data loss.

Contact & Legal Resources

For additional information regarding your rights and obligations, please review our complete Terms of Use, Privacy Policy, and Risk Disclosures.

For inquiries or support, contact us at: support@upcomers.com

Not a Deposit | Not Insured | May Lose Value

Effective Date: December 15, 2025