Terms of Service & Privacy Policy

This is the short version, written so you don't have to read the rest unless you want to. EquityZhen is a hybrid hedge-fund-style trading platform that lets you trade crypto, US-listed equities, and a small set of pre-IPO allocations — most notably SPCX, our fractional SpaceX pre-IPO product — from a single account.

• You must be 18 or older and not in a sanctioned jurisdiction.
• Withdrawals require completed KYC. Trading is open immediately after sign-up.
• New accounts receive a $1,000 promotional bonus credit. Bonus funds may cover at most 20% of any single buy or withdrawal — at least 80% must come from real cash.
• Crypto, equities, and pre-IPO allocations involve real risk of loss. Past performance is not indicative of future results.
• We collect the minimum data needed to operate the service. We do not sell your data.

By creating an EquityZhen account, accessing our website, mobile interfaces, or APIs, or by clicking "I agree" on any onboarding screen, you accept these Terms of Service and the Privacy Policy below. If you do not agree, you may not use the service.

These terms form a binding agreement between you ("User") and EquityZhen Inc., a Delaware corporation ("EquityZhen", "we", "us").

You may use EquityZhen only if all of the following are true:

• You are at least 18 years old and have full legal capacity to enter into a contract.
• You are not a resident of a jurisdiction where the service is prohibited by law, including (without limitation) any country subject to OFAC sanctions.
• You have not previously been suspended or removed from EquityZhen for cause.
• You are not on any government list of restricted or sanctioned persons.

We may, at our sole discretion, refuse service or restrict features in any jurisdiction. Pre-IPO products are limited to accredited investors where required by applicable securities law.

You must provide a valid email and a password of at least eight characters to create an account. We do not require email verification at signup, but you are responsible for the accuracy of every detail you submit, including identity information collected for Know Your Customer ("KYC") and Anti-Money-Laundering ("AML") compliance.

KYC is required before any withdrawal of fiat or cryptocurrency. Trading and pre-IPO reservations may begin immediately after signup, but withdrawn funds cannot leave the platform until your KYC is verified. You are responsible for keeping your account credentials confidential and for all activity that occurs under your account.

EquityZhen currently provides:

• Crypto trading: spot trading of major digital assets including BTC, ETH, SOL, BNB, XRP, ADA, AVAX, DOT, LINK, POL, DOGE, INJ, ARB, OP, SUI, APT, and NEAR. Real-time pricing is sourced from Coinbase, Kraken, and Gate.io.
• Equity trading: US-listed equities including AAPL, TSLA, NVDA, MSFT, AMZN, GOOGL, META, JPM, and NFLX. Real-time market data is licensed from Finnhub.
• Pre-IPO reservations: a curated set of pre-IPO allocations including SPCX (SpaceX) at a locked-in price of $420 per share.
• Custodial wallet: deposit addresses for BTC and EVM (USDT and USDC on Ethereum and Base) and SOL networks.

We are not a bank, broker-dealer, or registered investment adviser. We do not provide investment advice. Any information shown on our platform is for general purposes only and should not be relied on as a recommendation to buy or sell any asset.

When you place a market order, it fills immediately at the best available price using an aggregated price feed. Limit and stop-limit orders remain on the book until they fill or you cancel them; reserved funds are returned in full on cancellation.

Crypto assets in your EquityZhen account are held by our custody partners and are segregated from operational funds. Deposit addresses assigned to you are unique and non-rotating during normal operation.

SPCX is a fractional pre-IPO allocation product. When you reserve SPCX, your USD cash is converted to fractional share entitlements at a fixed price of $420.00 per share. Your reservation is recorded in your account holdings and may be increased ("topped up") at any time before institutional book closes.

SPCX entitlements are not registered securities at the time of reservation. Final share delivery is contingent on the issuer (SpaceX) completing an initial public offering or a similar liquidity event. EquityZhen makes no representation that any such event will occur.

Trading fees are tiered (Basic → Silver → Gold → Platinum → Diamond) and improve as your 30-day trailing volume increases. Maker and taker fees for the Basic tier are 0.10% and 0.15% respectively; Diamond drops to 0.05% maker and 0.08% taker.

We may run time-limited promotions (signup bonuses, referral rewards, staking yields, competition prize pools). All promotions are subject to additional terms presented at the time of the offer.

New accounts receive a $1,000 promotional bonuscredited to a separate bonus_balance. Bonus funds are tradable but partially restricted:

• Any single buy order may be funded for at most 20% from bonus; the remaining 80% (or more) must come from real cash.
• Any single withdrawal may be funded for at most 20% from bonus, with at least 80% drawn from real cash.
• Sell proceeds always credit to cash. Bonus is a one-way promotional coupon.
• If you cancel a limit order, the reservation is refunded to its original buckets (cash and bonus) in the original proportions.

We reserve the right to clawback bonus funds and any winnings derived from them in cases of abuse, including (without limitation) multi-account farming, wash trading, and reservation flipping.

Deposits: the minimum crypto deposit is $500 USD-equivalent. Smaller deposits may not be credited and may incur recovery fees. We support BTC on the Bitcoin network, USDT and USDC on Ethereum and Base, and SOL on Solana. Deposits credit after the required number of network confirmations.

Withdrawals: minimum withdrawal is $10. Withdrawals require completed KYC and are subject to the 80/20 funding rule (Section 8). We may delay or refuse withdrawals where AML, sanctions, or fraud signals warrant additional review.

Trading involves substantial risk of loss and is not suitable for every investor.

• Crypto assets are volatile. You may lose your entire investment, sometimes very quickly.
• Equities are subject to market, sector, and idiosyncratic risk.
• Pre-IPO products (including SPCX) are illiquid, may not deliver, and have no public market price.
• Past performance is not indicative of future results.
• Network outages, exchange outages, and order-book gaps can prevent execution at the price displayed.

You are solely responsible for any trades or reservations placed under your account. EquityZhen does not provide investment advice.

You agree not to use EquityZhen to:

• Violate any applicable law or regulation, including sanctions and securities laws.
• Launder money, finance terrorism, or facilitate any other crime.
• Manipulate any market, including wash trading, layering, spoofing, or pump-and-dump schemes.
• Open multiple accounts to abuse promotions including signup bonuses.
• Probe, scan, or otherwise test the vulnerability of the service without our written consent.
• Reverse-engineer or scrape the platform beyond the limits set by our public APIs.

We may suspend or terminate accounts engaged in prohibited activities and may report such activity to law enforcement.

The remainder of this document is EquityZhen's privacy policy. It explains what personal data we collect, how we use it, who we share it with, how long we keep it, and your rights over it.

• Account data: email, password hash, optional full name, phone, country, KYC documents and metadata.
• Trading data: orders, trades, holdings, deposits, withdrawals, reservations, fee tier, balances.
• Device and usage data: IP address, browser type, device fingerprint, pages viewed, actions taken, session timings.
• Communications: messages you send us through support channels.

• To operate the platform — execute trades, settle reservations, credit deposits, debit withdrawals.
• To comply with KYC, AML, sanctions, and tax-reporting obligations.
• To detect and prevent fraud, market manipulation, and abuse.
• To improve the service through aggregate analytics.
• To send you transactional, security, and (with your consent) marketing emails.

We do not sell your personal data.

We share the minimum data required with vetted partners to operate the service:

• Market data: Coinbase, Kraken, Gate.io, and Finnhub provide price feeds and order book snapshots. These providers do not receive your identity.
• KYC and AML: identity-verification vendors receive your KYC documents and personal data on a need-to-know basis.
• Infrastructure: cloud hosting (Vercel for the frontend, dedicated infrastructure for the API and database).
• Payments and banking partners for fiat rails when supported.
• Law enforcement when legally compelled.

EquityZhen uses two categories of browser storage:

• Strictly necessary: session token in localStorage to keep you signed in; cookie-consent flag.
• Optional: usage analytics (only when you accept the cookie banner). You can change this preference at any time from your account settings.

We do not embed advertising or cross-site tracking pixels. We do not use fingerprinting cookies.

Passwords are stored hashed with bcrypt at a work factor of 12. Session tokens are signed with HMAC-SHA-256 and expire after 7 days. All traffic between your browser and our servers is encrypted with TLS 1.2 or higher. Internal access to production data is restricted by role and audited.

You are responsible for the security of your own credentials. Enable two-factor authentication in Settings for additional protection.

Depending on where you live (notably the EEA, UK, California, and similar jurisdictions), you have the right to:

• Access a copy of the personal data we hold about you.
• Correct inaccurate or incomplete data.
• Request deletion of your data, subject to legal retention requirements (Section 19).
• Object to or restrict certain processing.
• Port your data to another service in a structured, machine-readable format.
• Withdraw consent for marketing communications at any time.

To exercise any of these rights, contact us using the details in Section 23.

We retain account, transaction, and KYC data for the longer of (a) seven years after account closure or (b) any period required by applicable law (typically five to seven years for AML records). Aggregated, de-identified analytics may be retained indefinitely.

You may close your account at any time from Settings, subject to settlement of any open positions, pending withdrawals, and KYC verification (if you have a withdrawable balance). We may suspend or terminate your account, with or without notice, for any breach of these terms or where required by law.

Closure does not waive amounts owed to or by us, and certain provisions (including risk disclosures, indemnification, and governing law) survive closure.

We may update these terms from time to time. Material changes will be communicated by email or via a prominent notice on the platform. Continued use of the service after the effective date constitutes acceptance of the updated terms. If you don't agree, your remedy is to close your account.

These terms are governed by the laws of the State of Delaware, without regard to its conflict-of-laws rules. Any dispute arising out of or relating to these terms or your use of the service shall be resolved by binding arbitration in Wilmington, Delaware, under the rules of the American Arbitration Association. You waive any right to a jury trial and to participate in a class action.

For any questions about these terms, your data, or to exercise any right described above:

• General: support@equityzhen.com
• Privacy & data requests: privacy@equityzhen.com
• Security disclosures: security@equityzhen.com

EquityZhen Inc., 1209 Orange Street, Wilmington, DE 19801, USA.