Terms of Use

Effective Date: 3 May 2026

1. Definitions and Interpretation

1.1 Definitions

In these Terms of Use (the “Terms”), unless the context otherwise requires, the following capitalised terms shall have the meanings set out below:

“Account” means the registered user account created by you on the Platform to access and use the Services.

“Applicable Law” means all applicable laws, statutes, regulations, rules, orders, directives, and guidelines of any governmental or regulatory authority, including but not limited to the Financial Conduct Authority (FCA), His Majesty’s Revenue & Customs (HMRC), and the Information Commissioner’s Office (ICO).

“Challenge” or “Evaluation” means the trading assessment programme(s) offered by ZkUmbra which a Trader must successfully complete in order to qualify for a Funded Account.

“Funded Account” means the simulated or live trading account provided to a Trader upon successful completion of an Evaluation, subject to the terms and conditions applicable thereto.

“Intellectual Property” means all patents, copyrights, trademarks, trade names, service marks, domain names, trade secrets, know-how, database rights, design rights, and all other intellectual property rights, whether registered or unregistered.

“Platform” means the ZkUmbra proprietary trading platform, including the website, web application, mobile applications, APIs, dashboards, and all associated infrastructure.

“Profit Split” means the agreed percentage of net profits generated on a Funded Account that is payable to the Trader in accordance with the applicable plan terms.

“Services” means all services offered by ZkUmbra through the Platform, including but not limited to Evaluations, Funded Accounts, educational content, analytics tools, and customer support.

“Trader” or “you” or “your” means the individual who registers for an Account and uses the Services.

“Trading Rules” means the rules, parameters, and conditions governing trading activity on Funded Accounts as published on the Platform and amended from time to time.

“ZkUmbra”, “we”, “us”, or “our” means Educhain Ltd, a company registered in England and Wales (Company Number as applicable), with its registered office at 128 City Road, London, EC1V 2NX, trading as ZkUmbra.

1.2 Interpretation

References to “person” include individuals, bodies corporate, partnerships, and unincorporated associations.

Headings are for convenience only and shall not affect interpretation.

Words in the singular include the plural and vice versa.

Any reference to legislation includes all subordinate legislation and any amendments, re-enactments, or replacements thereof.

2. Important Regulatory Notice and Nature of Services

PLEASE READ THIS SECTION CAREFULLY. IT DEFINES THE LEGAL AND REGULATORY NATURE OF ZKUMBRA AND THE SERVICES WE PROVIDE.

2.1 Corporate Status

Educhain Ltd, trading as ZkUmbra, is a private limited company incorporated in England and Wales with its registered office at 128 City Road, London, EC1V 2NX. ZkUmbra is a trader evaluation and educational platform. We are not a brokerage, broker-dealer, investment firm, credit institution, payment institution, electronic money institution, financial institution, or provider of regulated financial services of any kind.

2.2 Simulated Trading Environment

All trading activity conducted on the ZkUmbra Platform takes place in a fully simulated (demo) environment for skill assessment, performance evaluation, and educational purposes only. No real capital is traded by users at any time. Users do not receive access to live trading accounts, and no user funds are placed at risk in financial markets through the Platform.

Our Evaluation programmes and Funded Accounts use simulated market data and demo-based performance models to assess a participant’s trading discipline, risk management capabilities, and consistency. Any references to “profit”, “loss”, “profit split”, “payout”, “returns”, “funding”, or “funded account” on the Platform, in these Terms, or in any marketing materials refer exclusively to performance outcomes achieved within simulated environments and do not represent actual trading profits, investment returns, or income derived from live financial markets.

2.3 Not Regulated Financial Services

ZkUmbra is not authorised or regulated by the Financial Conduct Authority (FCA), the Prudential Regulation Authority (PRA), or any other financial services regulator in the United Kingdom or elsewhere. The Services provided by ZkUmbra do not constitute and shall not be construed as:

Investment services or activities within the meaning of the Financial Services and Markets Act 2000 (FSMA) or the Markets in Financial Instruments Directive (MiFID II, as onshored into UK law)

Dealing in investments as principal or agent (Articles 14 and 21 of the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 (RAO))

Arranging deals in investments (Article 25 RAO)

Managing investments or operating a collective investment scheme (Articles 37 and 51 RAO)

Advising on investments (Article 53 RAO)

Operating a multilateral trading facility (MTF), organised trading facility (OTF), or any other trading venue

Payment services within the meaning of the Payment Services Regulations 2017

Consumer credit or consumer hire agreements under the Consumer Credit Act 1974

You acknowledge that you are not a client, customer, or investor of ZkUmbra for the purposes of any financial services legislation, and that the protections afforded to clients of regulated firms (including the Financial Services Compensation Scheme (FSCS) and the Financial Ombudsman Service (FOS)) do not apply to your use of the Services.

2.4 Nature of Fees

All programme fees charged by ZkUmbra are paid solely in consideration for access to the Platform’s evaluation infrastructure, educational tools, simulated trading environment, customer support, and associated operational services. These fees are not and shall not be construed as deposits, investments, capital contributions, margin payments, collateral, or consideration for any financial instrument or service. Fees do not create any debtor-creditor, investor-investee, or trust relationship between you and ZkUmbra.

2.5 Performance-Based Compensation

Any compensation, reward, or payout made to a Trader is based solely on their demonstrated performance within the simulated trading environment and is subject to the terms, conditions, and rules of the applicable programme. Such payments represent contractual compensation for skill demonstration under a services agreement and do not constitute trading profits, investment returns, dividends, interest, or any form of income derived from financial market activity.

2.6 No Financial or Investment Advice

ZkUmbra does not provide, and nothing on the Platform shall be construed as, financial advice, investment advice, tax advice, legal advice, or trading recommendations. All content, educational materials, market commentary, analysis, and information provided through the Platform are for general informational and educational purposes only. You should seek independent professional advice from a qualified financial adviser, solicitor, or accountant before making any financial decisions. ZkUmbra accepts no responsibility for any financial decisions made by users based on content available on the Platform.

2.7 Risk Acknowledgement

You acknowledge and agree that: (a) trading in financial instruments, including foreign exchange, contracts for difference (CFDs), commodities, indices, equities, and digital assets, involves a high degree of risk; (b) past performance in a simulated environment is not indicative of future results in live markets; (c) simulated trading results have inherent limitations and do not reflect real market conditions, slippage, liquidity constraints, or the psychological impact of trading with real capital; and (d) ZkUmbra makes no representation or warranty that skills demonstrated in the simulated environment will translate to profitability in live trading.

3. Acceptance of Terms

By accessing, browsing, registering for, or using the Platform or any of the Services, you acknowledge that you have read, understood, and agree to be bound by these Terms, our Privacy Policy, our Cookie Policy, and any additional terms, guidelines, or rules applicable to specific Services (collectively, the “Agreement”).

If you do not agree to these Terms in their entirety, you must immediately cease using the Platform and Services. Your continued use of the Platform constitutes ongoing acceptance of these Terms as amended from time to time.

These Terms constitute a legally binding agreement between you and Educhain Ltd. You represent and warrant that you have the legal capacity and authority to enter into this Agreement.

4. Eligibility

To use the Services, you must:

Be at least 18 years of age (or the age of majority in your jurisdiction, whichever is greater)

Not be a resident or national of any country subject to comprehensive trade sanctions or embargoes imposed by the United Kingdom, the European Union, the United States, or the United Nations (including but not limited to North Korea, Iran, Syria, Cuba, and the Crimea, Donetsk, and Luhansk regions of Ukraine)

Not be a Specially Designated National, blocked person, or otherwise subject to sanctions administered by OFSI (Office of Financial Sanctions Implementation), OFAC, or equivalent authorities

Be legally permitted under the laws of your jurisdiction to access and use the Services

Provide accurate, complete, and current information during the registration and verification process

Not have previously been suspended or permanently banned from the Platform

We reserve the right to refuse registration, suspend, or terminate any Account if we reasonably believe that any of the eligibility criteria are not met or that you have provided false, misleading, or incomplete information.

5. Account Registration and Verification

5.1 Registration

To access certain features of the Platform, you must create an Account by providing the required information, including your full legal name, email address, date of birth, and country of residence. You must provide accurate, truthful, and complete information and promptly update any changes.

5.2 Identity Verification (KYC/AML)

In compliance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended), and in accordance with our obligations as a responsible business, we require all Traders to complete identity verification (Know Your Customer) and anti-money laundering checks before accessing Funded Accounts or receiving any payouts. You agree to provide such documentation and information as we may reasonably request.

5.3 Account Security

You are solely responsible for maintaining the confidentiality and security of your Account credentials, including your password and any two-factor authentication methods. You must immediately notify us at Legal@educhain.fyi if you become aware of any unauthorised access to or use of your Account. ZkUmbra shall not be liable for any loss or damage arising from your failure to protect your Account credentials.

6. Description of Services

6.1 Evaluation Programmes

ZkUmbra offers trading Evaluation programmes through which Traders may demonstrate their trading skills and risk management abilities. Evaluation programmes are subject to specific rules, targets, and parameters as published on the Platform. Successful completion of an Evaluation may, at our sole discretion, entitle the Trader to a Funded Account.

6.2 Funded Accounts

Funded Accounts are trading accounts provided to qualified Traders. All trading on Funded Accounts is subject to the Trading Rules. The nature of the Funded Account (whether simulated or live) shall be as specified in the applicable plan documentation.

6.3 Profit Splits and Payouts

Traders who generate net profits on their Funded Accounts may be entitled to a Profit Split as specified in the applicable plan terms. Payouts are subject to the following conditions:

Compliance with all Trading Rules and these Terms

Successful completion of identity verification and KYC/AML checks

No outstanding breaches, disputes, or investigations relating to the Trader’s Account

Minimum payout thresholds and payout schedules as published on the Platform

ZkUmbra reserves the right to withhold, delay, or reverse any payout where there are reasonable grounds to suspect fraud, manipulation, breach of Trading Rules, or other prohibited conduct

6.4 No Investment Advice

ZkUmbra does not provide investment advice, financial advice, tax advice, or trading signals. Any educational content, market analysis, or information provided through the Platform is for informational purposes only and does not constitute a recommendation or solicitation to buy, sell, or hold any financial instrument. You acknowledge that trading involves substantial risk of loss and that you are solely responsible for your trading decisions.

7. Trading Rules and Prohibited Conduct

7.1 Trading Rules

All trading activity on the Platform must comply with the Trading Rules as published on the Platform and updated from time to time. The Trading Rules form an integral part of these Terms. Key rules include, without limitation, maximum daily loss limits, maximum overall drawdown limits, minimum and maximum trading days, lot size restrictions, and permissible trading strategies.

7.2 Prohibited Conduct

The following activities are strictly prohibited and constitute a material breach of these Terms:

Account sharing, transferring, selling, or allowing any third party to access or operate your Account

Use of third-party trade copiers, signal services, or automated trading systems that are not expressly approved by ZkUmbra

Exploiting platform latency, price feed errors, arbitrage between accounts, or any form of market manipulation

Hedging or coordinating trades across multiple ZkUmbra accounts (whether held by the same or different individuals)

Use of high-frequency trading (HFT) strategies, tick scalping, or exploiting execution anomalies

Reverse engineering, decompiling, or otherwise attempting to access the source code of the Platform

Circumventing, disabling, or interfering with any security, access control, or risk management features of the Platform

Using the Services for money laundering, terrorist financing, or any other unlawful purpose

Impersonating another person or entity, or misrepresenting your identity, affiliation, or qualifications

Engaging in any conduct that is abusive, harassing, threatening, defamatory, or discriminatory towards ZkUmbra staff, contractors, or other Traders

Any other conduct that ZkUmbra reasonably determines to be manipulative, fraudulent, or contrary to the spirit of these Terms or the Trading Rules

7.3 Consequences of Breach

In the event of a breach of the Trading Rules or any prohibited conduct, ZkUmbra reserves the right, at its sole and absolute discretion, to take one or more of the following actions without prior notice:

Issue a formal warning

Immediately suspend or restrict access to the Platform and/or Funded Account

Reset, reduce, or revoke the Funded Account

Forfeit any accrued but unpaid profits or Profit Splits

Permanently terminate the Trader’s Account

Report the conduct to relevant law enforcement or regulatory authorities

Pursue any and all legal remedies available under Applicable Law

8. Fees, Payments, and Refunds

8.1 Fees

Access to certain Services, including Evaluation programmes, requires payment of fees as listed on the Platform. All fees are quoted in the applicable currency and, unless otherwise stated, are inclusive of VAT where applicable. Fees are subject to change, and the current fee schedule shall be as displayed on the Platform at the time of purchase.

8.2 Payment Methods

Payments may be made using the payment methods available on the Platform, which may include credit/debit cards, bank transfers, and cryptocurrency. All payments are processed through secure third-party payment processors. ZkUmbra does not store your full payment card details.

8.3 Refund Policy

Refunds are governed by our Refund Policy as published on the Platform. In general:

Evaluation fees are non-refundable once the Trader has commenced trading on the Evaluation account

Where a Trader has not commenced trading, a refund may be requested within 14 days of purchase in accordance with the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013

Refund requests must be submitted in writing to Legal@educhain.fyi

ZkUmbra reserves the right to refuse a refund where there is evidence of abuse of the refund policy or prohibited conduct

9. Intellectual Property

All Intellectual Property rights in and to the Platform, the Services, and all content, materials, software, algorithms, designs, logos, trademarks, documentation, and data provided through the Platform are and shall remain the exclusive property of Educhain Ltd or its licensors. Nothing in these Terms grants you any right, title, or interest in any Intellectual Property other than the limited, non-exclusive, non-transferable, revocable licence to access and use the Platform for its intended purpose in accordance with these Terms.

You shall not copy, reproduce, distribute, modify, create derivative works from, publicly display, publicly perform, republish, download, store, transmit, or exploit any content or material from the Platform without our prior written consent, except as expressly permitted by Applicable Law.

10. Limitation of Liability

10.1 Exclusion of Certain Liabilities

To the maximum extent permitted by Applicable Law, ZkUmbra, its directors, officers, employees, agents, affiliates, and licensors shall not be liable for:

Any indirect, incidental, special, consequential, punitive, or exemplary damages, including but not limited to loss of profits, revenue, data, goodwill, business opportunity, or anticipated savings, whether arising in contract, tort (including negligence), strict liability, or otherwise

Any loss or damage arising from or in connection with your trading activity, trading decisions, or the performance of any Funded Account

Any loss resulting from interruption, suspension, delay, or unavailability of the Platform or Services, including due to system maintenance, technical failures, cyberattacks, or force majeure events

Any loss resulting from unauthorised access to your Account caused by your failure to maintain adequate security of your credentials

Any actions taken by ZkUmbra in accordance with its rights under these Terms, including Account suspension, termination, or profit forfeiture

10.2 Cap on Liability

Subject to Section 9.3, ZkUmbra’s total aggregate liability to you in respect of all claims arising out of or in connection with these Terms or the Services shall not exceed the greater of: (a) the total fees paid by you to ZkUmbra in the twelve (12) months immediately preceding the event giving rise to the claim; or (b) one hundred pounds sterling (£100).

10.3 Nothing Excluded

Nothing in these Terms shall exclude or limit liability for: (a) death or personal injury caused by negligence; (b) fraud or fraudulent misrepresentation; (c) any liability which cannot be excluded or limited under Applicable Law, including under the Consumer Rights Act 2015 (where applicable).

11. Indemnification

You agree to indemnify, defend, and hold harmless ZkUmbra, its directors, officers, employees, agents, affiliates, successors, and assigns from and against any and all claims, liabilities, damages, losses, costs, and expenses (including reasonable legal fees) arising out of or in connection with:

Your use of the Platform and Services

Your breach of these Terms, the Trading Rules, or any Applicable Law

Your violation of any third-party rights, including Intellectual Property rights

Any misrepresentation made by you

Any tax liability arising from your use of the Services or receipt of payouts

12. Disclaimers

THE PLATFORM AND SERVICES ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED, OR STATUTORY, INCLUDING BUT NOT LIMITED TO IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT.

ZkUmbra does not warrant that: (a) the Platform will be available at all times or free from errors, interruptions, or security vulnerabilities; (b) any defects will be corrected; (c) the results obtained through the Platform will be accurate, reliable, or meet your expectations; or (d) the Platform is free from viruses, malware, or other harmful components.

Past performance on an Evaluation or Funded Account is not indicative of future results. Trading in financial instruments involves a high degree of risk and may not be suitable for all individuals.

13. Termination

13.1 Termination by You

You may terminate your Account at any time by submitting a written request to Legal@educhain.fyi. Termination of your Account does not entitle you to a refund of any fees paid. Any accrued but unpaid Profit Split shall be processed in accordance with the applicable payout schedule, subject to compliance with these Terms.

13.2 Termination by ZkUmbra

ZkUmbra may suspend or terminate your Account, with or without cause, at any time and without prior notice, including but not limited to situations where:

You breach any provision of these Terms or the Trading Rules

We are required to do so by Applicable Law or by order of a court, regulatory authority, or law enforcement agency

We suspect fraudulent, manipulative, or unlawful activity

Your Account has been inactive for a period of 12 consecutive months or more

Continued provision of the Services to you is no longer commercially viable

13.3 Effect of Termination

Upon termination: (a) your right to access and use the Platform and Services shall immediately cease; (b) any outstanding obligations (including indemnification and limitation of liability) shall survive; (c) Sections 9, 10, 11, 12, 14, 15, 16, and 17 shall survive termination.

14. Dispute Resolution

14.1 Complaints

If you have a complaint about the Services, please contact us in writing at Legal@educhain.fyi. We will acknowledge receipt of your complaint within 5 business days and endeavour to resolve the matter within 8 weeks.

14.2 Mediation

If a dispute cannot be resolved through our internal complaints procedure, either party may refer the matter to mediation administered by the Centre for Effective Dispute Resolution (CEDR) in London, in accordance with the CEDR Model Mediation Procedure. Both parties agree to participate in good faith in any mediation proceedings.

14.3 Jurisdiction

Subject to the mediation clause above, these Terms shall be governed by and construed in accordance with the laws of England and Wales, and the courts of England and Wales shall have exclusive jurisdiction to settle any dispute arising out of or in connection with these Terms.

15. Force Majeure

ZkUmbra shall not be liable for any failure or delay in performance of its obligations under these Terms to the extent that such failure or delay is caused by circumstances beyond its reasonable control, including but not limited to acts of God, natural disasters, pandemics, epidemics, war, terrorism, civil unrest, government actions or orders, sanctions, embargoes, strikes, labour disputes, power failures, internet or telecommunications failures, cyberattacks, exchange or market disruptions, and regulatory changes (each a “Force Majeure Event”). ZkUmbra shall use reasonable endeavours to mitigate the effect of any Force Majeure Event and to resume performance as soon as reasonably practicable.

16. General Provisions

16.1 Entire Agreement

These Terms, together with the Privacy Policy, Cookie Policy, Trading Rules, and any supplementary terms, constitute the entire agreement between you and ZkUmbra with respect to the subject matter hereof and supersede all prior or contemporaneous communications, representations, or agreements, whether written or oral.

16.2 Severability

If any provision of these Terms is held to be invalid, illegal, or unenforceable by a court of competent jurisdiction, such provision shall be severed and the remaining provisions shall continue in full force and effect.

16.3 Waiver

No failure or delay by ZkUmbra in exercising any right, power, or remedy under these Terms shall operate as a waiver thereof, nor shall any single or partial exercise preclude any further exercise or the exercise of any other right, power, or remedy.

16.4 Assignment

You may not assign, transfer, or delegate any of your rights or obligations under these Terms without our prior written consent. ZkUmbra may assign, transfer, or delegate any of its rights or obligations under these Terms at any time without your consent, including in connection with a merger, acquisition, corporate reorganisation, or sale of all or substantially all of its assets.

16.5 No Third-Party Rights

These Terms do not confer any rights on any person or party other than the parties hereto and their respective successors and permitted assigns under the Contracts (Rights of Third Parties) Act 1999.

16.6 Notices

All notices required or permitted under these Terms shall be in writing and shall be deemed given when: (a) delivered personally; (b) sent by recorded delivery post; or (c) sent by email to the address on file. Notices to ZkUmbra shall be sent to Legal@educhain.fyi or to Educhain Ltd, 128 City Road, London, EC1V 2NX.

16.7 Amendments

ZkUmbra reserves the right to modify these Terms at any time. Material changes will be communicated to you via email or by posting a notice on the Platform at least 30 days before the changes take effect. Your continued use of the Services after the effective date of any amended Terms constitutes your acceptance of the amendments. If you do not agree with the amended Terms, you must cease using the Services and close your Account.

17. Anti-Money Laundering and Counter-Terrorist Financing

ZkUmbra is committed to the prevention of money laundering, terrorist financing, and financial crime. We maintain a comprehensive AML/CTF programme in accordance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended), the Proceeds of Crime Act 2002 (POCA), the Terrorism Act 2000, and all relevant JMLSG (Joint Money Laundering Steering Group) guidance.

You acknowledge and agree that:

We may conduct ongoing monitoring of your Account and trading activity for suspicious activity

We may be required to file Suspicious Activity Reports (SARs) with the National Crime Agency (NCA) without notifying you (tipping-off is a criminal offence under POCA)

We may freeze, suspend, or close your Account and withhold funds if we have reasonable grounds to suspect money laundering or terrorist financing

Failure to cooperate with our KYC/AML requirements may result in Account closure and reporting to the relevant authorities

18. Regulatory Disclosure

ZkUmbra is a proprietary trading evaluation platform operated by Educhain Ltd. ZkUmbra does not provide regulated financial services and is not authorised or regulated by the Financial Conduct Authority (FCA) or any other financial services regulator. The Evaluations and Funded Accounts offered through the Platform do not constitute investment services, portfolio management, or the arrangement of deals in investments within the meaning of the Financial Services and Markets Act 2000 (FSMA).

Trading in financial instruments, including but not limited to foreign exchange, contracts for difference (CFDs), commodities, indices, and cryptocurrencies, carries a high level of risk and may not be suitable for all investors. You should carefully consider your financial situation, investment experience, and risk appetite before participating in any Evaluation or Funded Account. You should seek independent financial, legal, and tax advice where appropriate.

19. Contact Information

For any questions, complaints, or legal notices relating to these Terms, please contact us at:

Company: Educhain Ltd (trading as ZkUmbra)

Address: 128 City Road, London, EC1V 2NX

Email: Legal@educhain.fyi

© 2026 Educhain Ltd trading as ZkUmbra. All rights reserved.