Trade Management Mastery
Legal Documents
Draft Suite v1.0 - For Legal Review Only
Draft documents - for legal review only - not for public use until reviewed and approved by qualified legal counsel
Draft - Requires Legal Review
Privacy Policy
Trade Management Mastery - Global Privacy Policy
Version: 1.0 Draft
Effective Date: [INSERT DATE]
Last Updated: [INSERT DATE]
Covers

Australian Privacy Act 1988 - GDPR (EU/EEA) - UK GDPR - CCPA (California) - Global visitors

1. Who We Are

[TMM ENTITY NAME] (referred to in this policy as "TMM", "we", "us", or "our") operates the Trade Management Mastery platform, including the website at trademanagementmastery.com, all associated subdomains, the TMM Community on Circle, the TMM newsletter on Beehiiv, and all TMM products and services.

Registered entity: [COMPANY NAME - Cyprus entity or operating entity TBC with legal counsel]

Principal place of operation: Perth, Western Australia, Australia

Contact email: [PRIVACY@TRADEMANAGEMENTMASTERY.COM]

2. What This Policy Covers

This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you:

3. Information We Collect
3.1 Information You Provide Directly
3.2 Information We Collect Automatically
3.3 Information From Third Parties
3.4 Information We Do NOT Collect
4. How We Use Your Information
PurposeLegal Basis (GDPR)Examples
Providing our servicesContract performanceDelivering purchased products, processing subscriptions, granting access
Account managementContract performanceCreating and maintaining your account, authentication
CommunicationsContract / Legitimate interestTransactional emails, subscription confirmations, service updates
Newsletter and marketingConsentDaily Edge newsletter, product announcements. You may unsubscribe at any time.
Analytics and improvementLegitimate interestUnderstanding how the website is used, improving products and content
Legal complianceLegal obligationTax records, responding to lawful requests from authorities
Fraud preventionLegitimate interest / Legal obligationDetecting and preventing fraudulent transactions or abuse
5. Sharing Your Information

We do not sell your personal information. We share data only in the following circumstances:

5.1 Service Providers
ProviderPurposeLocation
StripePayment processingUSA (Privacy Shield / SCCs)
WhopIndicator and product deliveryUSA
Circle.soCommunity platformUSA
BeehiivNewsletter distributionUSA
Google AnalyticsWebsite analyticsUSA
GoDaddyWebsite hostingUSA
BybitExchange integration (Engine bot subscribers only - via your own account)Dubai, UAE
5.2 Other Sharing
6. International Data Transfers

TMM operates globally. Your information may be transferred to and processed in countries other than your country of residence, including Australia, the United States, and Cyprus. These countries may have different data protection laws.

Where we transfer data from the EU/EEA or UK to countries without an adequacy decision, we ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) with our service providers.

7. Data Retention
Data TypeRetention Period
Account informationDuration of account plus 3 years after closure
Transaction records7 years (tax and legal compliance)
Newsletter subscription dataUntil unsubscribe plus 1 year
Analytics data26 months (Google Analytics default)
Support communications2 years from last contact
Community posts and contentDuration of community membership; may be retained in anonymised form after deletion
8. Your Rights
8.1 EU/EEA and UK Users (GDPR)
8.2 California Residents (CCPA)
8.3 Australian Users

Australian residents have rights under the Australian Privacy Act 1988 (Cth) to access and correct their personal information and to make a complaint to the Office of the Australian Information Commissioner (OAIC).

To exercise any of these rights, contact us at [PRIVACY EMAIL]. We will respond within 30 days.

9. Security

We implement appropriate technical and organisational measures to protect your personal information, including SSL/TLS encryption for data in transit, access controls limiting data access to authorised personnel, use of reputable third-party processors with their own security certifications, and regular review of our security practices.

No method of transmission over the internet is 100% secure. We cannot guarantee absolute security but we take reasonable steps to protect your information.

10. Children's Privacy

TMM services are not directed to persons under 18 years of age. We do not knowingly collect personal information from minors. If you believe we have inadvertently collected information from a minor, please contact us immediately and we will delete it.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email (if you have an account) and by posting a notice on our website. Continued use of our services after changes are posted constitutes acceptance of the updated policy.

12. Contact Us

For privacy-related enquiries, requests to exercise your rights, or complaints:

Email: [PRIVACY@TRADEMANAGEMENTMASTERY.COM]
Website: trademanagementmastery.com
Entity: [REGISTERED ENTITY NAME AND ADDRESS]

Legal Review Notes

Confirm: (1) Which entity is the data controller - Cyprus company or Australian operating entity? (2) Is a Data Protection Officer required under GDPR given the scale of EU user data processing? (3) Confirm Bybit data sharing provisions match the actual API integration architecture. (4) Confirm adequacy of SCCs for each US-based processor given current EU-US data transfer landscape.

Draft - Requires Legal Review
Terms of Service
Trade Management Mastery - Terms Governing Use of All Products and Services
Version: 1.0 Draft
Effective Date: [INSERT DATE]
Important - Please Read

By accessing or using any TMM product or service, you agree to be bound by these Terms. If you do not agree, do not use our services. These Terms include a limitation of liability clause and a risk acknowledgement that affects your legal rights.

1. About TMM and These Terms

[TMM ENTITY NAME] ("TMM", "we", "us") operates Trade Management Mastery, a trading education platform providing educational content, tools, indicators, signals, and an algorithmic trading bot for cryptocurrency markets.

These Terms of Service ("Terms") govern your access to and use of all TMM products and services, including the website at trademanagementmastery.com, the TMM Community, all indicators, the TMM Engine bot, TMM Pulse signals, and any other products offered by TMM.

2. Educational Purpose - Not Financial Advice
Critical Disclaimer

All TMM products, services, content, indicators, signals, and tools are provided for educational and informational purposes only. Nothing provided by TMM constitutes financial advice, investment advice, trading advice, or any other form of professional financial service. TMM is not a licensed financial adviser, broker, dealer, or investment manager in any jurisdiction. All trading decisions are yours alone and are made entirely at your own risk.

3. Eligibility

You must be at least 18 years old to use TMM services. By using our services, you confirm that:

4. Your Account
4.1 Account Creation

Certain TMM products require you to create an account. You are responsible for maintaining the confidentiality of your account credentials and for all activity under your account. You must notify us immediately of any unauthorised use.

4.2 Accurate Information

You agree to provide accurate, current, and complete information during registration and to update this information to keep it accurate.

4.3 Account Termination

We reserve the right to suspend or terminate your account at any time for violation of these Terms, fraudulent activity, or any other reason at our discretion. You may close your account at any time by contacting us.

5. Subscriptions and Payment
5.1 Subscription Terms

Many TMM products are offered on a monthly subscription basis. By subscribing, you authorise us (or our payment processor Stripe or Whop) to charge your nominated payment method on a recurring monthly basis at the price shown at the time of purchase.

5.2 Pricing

Prices are displayed in USD unless otherwise stated. TMM reserves the right to change subscription prices. You will be given at least 30 days' notice of any price increase and may cancel before the increase takes effect.

5.3 Cancellation

You may cancel your subscription at any time. Cancellation takes effect at the end of the current billing period. You will retain access to the product until the end of the period you have paid for. See our Refund and Cancellation Policy for full details.

5.4 Founding Member Pricing

Where founding member pricing is offered, the locked price applies only to the specific product tier purchased and only for so long as the subscription remains active. Cancellation forfeits the founding member rate permanently.

6. Acceptable Use

You agree not to:

7. Intellectual Property

All TMM content, including but not limited to the trading methodology, indicators, software, course content, newsletters, graphics, videos, and brand assets, are the intellectual property of [TMM ENTITY NAME] or its licensors. These are protected by copyright, trade secret, and other applicable laws.

Your subscription grants you a limited, non-exclusive, non-transferable, revocable licence to access and use TMM products for your own personal, non-commercial trading education. This licence does not transfer any ownership rights to you.

8. TradingView Indicators

TMM indicators are delivered as invite-only protected Pine Script on TradingView. Your subscription grants you access to the indicator on your personal TradingView account only. You may not share, transfer, or attempt to replicate the indicator. Access is tied to your active subscription and will be revoked upon cancellation.

9. TMM Engine Bot and Pulse Signals

The TMM Engine and Pulse Signals products involve automated or semi-automated trading activity. By subscribing to these products, you specifically acknowledge and agree that:

Please also read the Bot and Signals EULA which forms part of these Terms for subscribers to TMM Engine and TMM Pulse.

10. Performance Data and Results

Any performance data, backtest results, paper trading results, or live trading results shared by TMM are presented for educational purposes only and are subject to the following important qualifications:

11. Disclaimer of Warranties

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, TMM PROVIDES ALL PRODUCTS AND SERVICES "AS IS" AND "AS AVAILABLE" WITHOUT ANY WARRANTY OF ANY KIND, EXPRESS OR IMPLIED. TMM SPECIFICALLY DISCLAIMS ANY WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT.

We do not warrant that our services will be uninterrupted, error-free, or free from viruses or other harmful components. We do not warrant that any trading strategy, signal, indicator, or bot will be profitable.

12. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, TMM, ITS OFFICERS, DIRECTORS, EMPLOYEES, PARTNERS, AND AFFILIATES SHALL NOT BE LIABLE FOR:

In jurisdictions where the exclusion or limitation of liability for consequential or incidental damages is not permitted, TMM's liability shall be limited to the maximum extent permitted by law.

In any event, TMM's total aggregate liability to you for any claim shall not exceed the total subscription fees you paid to TMM in the three months immediately preceding the event giving rise to the claim.

13. Indemnification

You agree to indemnify, defend, and hold harmless TMM and its partners, officers, employees, and affiliates from any claim, loss, damage, liability, cost, or expense (including reasonable legal fees) arising from your use of TMM services, your violation of these Terms, or your violation of any third-party rights or applicable laws.

14. Governing Law and Dispute Resolution

Governing Law: These Terms shall be governed by and construed in accordance with the laws of [JURISDICTION - to be confirmed with legal counsel: Cyprus, Australia, or both depending on entity structure], without regard to conflict of law principles.

Dispute Resolution: Any dispute arising from these Terms or your use of TMM services shall first be addressed through good-faith negotiation. If unresolved within 30 days, disputes shall be submitted to binding arbitration in [JURISDICTION]. Nothing in this clause prevents either party from seeking emergency injunctive relief from a court of competent jurisdiction.

Jurisdiction for Australian users: Nothing in these Terms excludes any rights you have under the Australian Consumer Law that cannot be excluded by contract.

Jurisdiction for EU/UK users: Nothing in these Terms excludes any mandatory consumer protection rights applicable in your jurisdiction.

15. Changes to These Terms

We may update these Terms from time to time. We will give you at least 14 days' notice of material changes by email or website notice. Continued use of our services after the effective date constitutes acceptance of the updated Terms.

16. Miscellaneous
17. Contact

For questions about these Terms: [LEGAL@TRADEMANAGEMENTMASTERY.COM]

Legal Review Notes

Key items for counsel: (1) Confirm governing law clause given Cyprus entity structure and Australian operations. (2) Confirm arbitration clause is enforceable in target markets and does not conflict with mandatory consumer laws in Australia, EU, or UK. (3) Review limitation of liability cap (3 months fees) - is this commercially appropriate and enforceable? (4) Add specific AFSL analysis note - confirm whether Engine bot subscription constitutes a "financial service" under the Corporations Act.

Draft - Requires Legal Review
Risk Disclosure Statement
Specific to TMM Engine Bot, Pulse Signals, and Indicator Products
Version: 1.0 Draft
Effective Date: [INSERT DATE]
Please Read Carefully Before Subscribing

This Risk Disclosure Statement applies to all TMM subscribers, particularly subscribers to TMM Engine (bot), TMM Pulse (signals), and TMM Edge (indicators). You must read and understand this document before using any TMM trading-related product.

1. Acknowledgement of Risk

Cryptocurrency trading carries a substantial risk of financial loss. Trading on margin or with leverage amplifies both potential gains and potential losses. It is possible to lose some or all of your invested capital. You should not trade with money you cannot afford to lose.

By subscribing to any TMM product, you expressly acknowledge that:

2. General Cryptocurrency Market Risks
2.1 Market Volatility

Cryptocurrency markets are among the most volatile financial markets in existence. Prices can move dramatically within minutes or seconds due to news events, regulatory announcements, whale activity, exchange issues, or market sentiment shifts. A position that appears profitable can become a significant loss in a very short period.

2.2 Liquidity Risk

Some cryptocurrency assets have limited liquidity. In thin markets, large orders may significantly move the price, causing slippage between the intended execution price and the actual execution price. This affects both the opening and closing of positions.

2.3 Regulatory Risk

Cryptocurrency regulation is evolving rapidly across all jurisdictions. Changes in laws or regulatory approaches could affect the legality of cryptocurrency trading or certain trading strategies in your jurisdiction. It is your responsibility to ensure that your use of TMM products and your trading activities are lawful in your country of residence.

2.4 Exchange Risk

Trading occurs on third-party exchanges (principally Bybit for Engine subscribers). TMM has no control over exchange operations, liquidity, fees, technical failures, or the solvency of the exchange. Exchange failures, hacks, regulatory actions, or operational issues can result in partial or total loss of funds held on the exchange.

3. Algorithmic Bot Specific Risks (TMM Engine)
3.1 System and Technical Risk

The TMM Engine is an automated trading system that relies on continuous connectivity between the TMM software, the Bybit API, and your exchange account. The following technical risks may affect performance:

3.2 Strategy Risk

The TMM Engine employs a dual-strategy approach (trend following and mean reversion) with regime detection. The following strategy risks apply:

3.3 Backtest and Paper Trading Limitations

TMM publishes backtest results and paper trading results as part of its build-in-public approach. You must understand that:

3.4 Risk Settings Responsibility

The TMM Engine allows you to select risk levels (1%, 2%, or 3% per trade). You are solely responsible for selecting risk settings appropriate to your account size and risk tolerance. Setting inappropriate risk levels can result in significant losses.

4. Signal Service Specific Risks (TMM Pulse)
4.1 Manual Execution Risk

TMM Pulse delivers signals to your Telegram. You are responsible for deciding whether to act on each signal and for executing trades manually on your own exchange account. Risks specific to manual execution include:

4.2 Signal Interpretation

Signals provided by TMM Pulse are generated by the TMM Engine algorithm. They represent what the algorithm assessed as a valid trade setup based on its rules. They are not personalised recommendations for your specific situation and should not be treated as such.

5. Indicator Specific Risks (TMM Edge)

TMM indicators are tools designed to assist with trade analysis and are for educational purposes only. The following risks apply:

6. Leverage and Perpetual Futures

The TMM Engine trades Bybit perpetual futures, which are leveraged products. Trading with leverage means:

7. No Personalised Advice

TMM has not, and will not, consider your individual financial situation, investment objectives, tax position, or risk tolerance. Nothing provided by TMM should be treated as personalised financial, investment, or tax advice. Before trading, you should consider whether trading cryptocurrency perpetual futures is appropriate for your personal circumstances and, if in doubt, seek advice from a licensed financial adviser in your jurisdiction.

8. Jurisdiction-Specific Warnings
8.1 Australia

Cryptocurrency trading, including perpetual futures, may be subject to regulation by the Australian Securities and Investments Commission (ASIC). TMM does not hold an Australian Financial Services Licence (AFSL). You are responsible for ensuring your trading activities comply with Australian law.

8.2 European Union

Crypto-asset services in the EU are subject to the Markets in Crypto-Assets Regulation (MiCA). TMM is an educational platform and does not provide regulated crypto-asset services. EU residents should consider whether their trading activities are subject to applicable regulations in their member state.

8.3 United Kingdom

Cryptoasset activities in the UK are regulated by the Financial Conduct Authority (FCA). TMM is not FCA-registered or authorised. All TMM content accessible in the UK is provided for educational purposes only and should not be construed as a financial promotion.

8.4 United States

TMM does not provide services regulated by the SEC or CFTC. US residents should independently verify that their participation in cryptocurrency perpetual futures trading is lawful in their state and that their use of TMM products does not trigger any applicable securities or commodities regulations.

9. Your Acknowledgement

By subscribing to any TMM Engine, Pulse, or Edge product, you confirm that you have read and understood this Risk Disclosure Statement, that you accept the risks described, and that you are making an informed decision to proceed at your own risk.

Legal Review Notes

Key items: (1) Confirm AFSL analysis - does the Engine bot subscription constitute a financial service requiring a licence under the Corporations Act? This is the most critical legal question for TMM and must be answered before launch. (2) Confirm the EU section accurately reflects MiCA's treatment of educational platforms. (3) Confirm UK FCA financial promotions analysis - is a blanket educational disclaimer sufficient for UK-accessible content?

Draft - Requires Legal Review
General Disclaimer
Site-Wide Disclaimer - To Appear in Footer of Every Page
Version: 1.0 Draft
Effective Date: [INSERT DATE]
Two Versions Included

Short form for footer placement on every page. Long form for the dedicated Disclaimer page linked from the footer. Both are included below.

Short Form Disclaimer (Footer - Every Page)
Footer Text

This website and all associated content, products, and services are provided for educational and informational purposes only. Nothing on this website constitutes financial advice, investment advice, trading advice, or a recommendation to buy or sell any financial instrument or cryptocurrency. All trading involves significant risk of loss. Past performance is not indicative of future results. Always conduct your own research and consider seeking advice from a licensed financial adviser before making any trading decisions. Your results will vary. Trade Management Mastery is not a licensed financial services provider in any jurisdiction.

Long Form Disclaimer (Dedicated Disclaimer Page)
Educational Content Only

Trade Management Mastery (TMM) is a trading education platform. All content published on this website, in our newsletters, in our community, on our YouTube channels, on our social media accounts, and through any TMM product or service is provided for educational and informational purposes only.

Nothing provided by TMM, including but not limited to market analysis, trading methodology, indicators, signals, bot outputs, educational courses, coaching sessions, community discussions, or any other content, constitutes:

No Financial Services Licence

[TMM ENTITY NAME] does not hold an Australian Financial Services Licence (AFSL), is not registered with the Australian Securities and Investments Commission (ASIC) as a financial services provider, is not registered with or regulated by the Financial Conduct Authority (FCA) in the United Kingdom, is not registered as an investment adviser with the SEC in the United States, and does not hold any equivalent licence or registration in any other jurisdiction.

Trading Risk

Trading cryptocurrency, including cryptocurrency perpetual futures, carries a substantial risk of financial loss. Cryptocurrency markets are highly volatile. The use of leverage amplifies both potential gains and losses. It is possible to lose some or all of your invested capital.

You should never trade with money you cannot afford to lose.

Past Performance

Any performance data, backtest results, paper trading results, live trading results, or examples of trades shown by TMM are presented for educational purposes only. Past performance does not guarantee future results. Results shared by TMM team members, community members, or in any TMM content are not necessarily representative of typical results and individual outcomes will vary significantly based on market conditions, account size, risk settings, execution quality, and many other factors.

Build in Public

TMM operates a build-in-public approach, sharing bot development updates, backtest results, paper trading results, and live trading data. This is shared as a transparent educational record of the development process and not as a promise or projection of future performance. All figures shared are specifically attributed as backtest, paper trading, or live trading results.

Referral and Affiliate Relationships

TMM may receive referral commissions from exchange partners (including Bybit and Blofin) when you use our referral links to create an account. This is disclosed transparently on our links page. Referral relationships do not influence our educational content or trading methodology.

Third-Party Content

Any third-party tools, indicators, content, or products available through the TMM Market or recommended by community members are the responsibility of their respective creators. TMM does not endorse, guarantee, or warrant any third-party product and accepts no liability for losses arising from the use of third-party products.

Your Responsibility

You are solely responsible for:

Jurisdiction Notice

This website is accessible globally. TMM makes no representation that the products or services described are appropriate or available in all jurisdictions. Persons in jurisdictions where the provision of educational trading content, signals, or algorithmic tools may be restricted or regulated should seek local legal advice before using TMM services.

Contact

If you have questions about this disclaimer, please contact [LEGAL@TRADEMANAGEMENTMASTERY.COM].

This disclaimer was last updated: [DATE]. TMM reserves the right to update this disclaimer at any time.

Legal Review Notes

Key items: (1) Confirm the AFSL section accurately reflects TMM's position - if the bot subscription does constitute a financial service, the "no AFSL" language needs to be adjusted. (2) Confirm whether the UK FCA financial promotions analysis requires any additional specific language for UK-accessible content beyond the educational disclaimer. (3) Review whether "build in public" disclosures need any additional qualifications.

Post-Launch - Draft - Requires Legal Review
Cookie Policy
How Trade Management Mastery Uses Cookies and Tracking Technologies
Version: 1.0 Draft
Effective Date: [INSERT DATE]
1. What Are Cookies

Cookies are small text files stored on your device when you visit a website. They are widely used to make websites work, improve user experience, and provide analytics information to website operators. This policy explains what cookies we use and why, and how you can manage your preferences.

2. Cookies We Use
CategoryPurposeExamplesCan You Opt Out?
Strictly NecessaryRequired for the website to function. Cannot be disabled.Session authentication, security tokens, payment processing cookies (Stripe)No - required for service
FunctionalRemember your preferences and settingsLanguage preferences, remembered login, localStorage items (checklist state, journal data)Yes
AnalyticsHelp us understand how the website is used so we can improve itGoogle Analytics (page views, session data, traffic sources)Yes
Marketing / Third-PartyUsed by third-party platforms you connect withYouTube embedded player cookies, Circle.so platform cookies, Beehiiv newsletter trackingYes
3. Specific Third-Party Cookies
ProviderCookie PurposePrivacy Policy
Google AnalyticsWebsite analytics - pages visited, session duration, traffic sourcespolicies.google.com/privacy
YouTubeVideo player functionality when embedded videos are viewedpolicies.google.com/privacy
StripePayment processing and fraud preventionstripe.com/privacy
Circle.soCommunity platform functionality for logged-in memberscircle.so/privacy-policy
BeehiivNewsletter subscription and email trackingbeehiiv.com/privacy
WhopProduct access and subscription managementwhop.com/privacy-policy
4. localStorage

Some TMM tools (including the TMM Interactive Journal, the Operating System dashboard, and the Launch Roadmap checklist) use your browser's localStorage to save your data locally on your device. This data is not transmitted to TMM servers. It remains on your device and can be cleared by clearing your browser's site data.

5. Your Choices
5.1 Cookie Consent Banner

When you first visit the TMM website, you will be shown a cookie consent banner allowing you to accept or decline non-essential cookies. You can change your preferences at any time by clicking the "Cookie Settings" link in the footer of any page.

5.2 Browser Settings

Most browsers allow you to refuse or delete cookies through browser settings. Note that disabling cookies may affect the functionality of certain website features.

5.3 Google Analytics Opt-Out

You can opt out of Google Analytics tracking using the Google Analytics Opt-out Browser Add-on available at tools.google.com/dlpage/gaoptout.

5.4 Global Privacy Control

We respect Global Privacy Control (GPC) signals from your browser as a valid opt-out request for data sharing under applicable privacy laws including CCPA.

6. Contact

For cookie-related enquiries: [PRIVACY@TRADEMANAGEMENTMASTERY.COM]

Legal Review Notes

Key items: (1) A cookie consent management platform (Cookiebot, CookieYes, or similar) should be implemented to handle GDPR cookie consent properly - this policy alone is not sufficient for technical compliance. (2) Confirm whether all third-party providers listed are accurate at time of launch. (3) Confirm localStorage usage does not trigger any GDPR obligations around local processing.

Post-Launch - Draft - Requires Legal Review
Refund and Cancellation Policy
Trade Management Mastery - Subscription and Purchase Policies
Version: 1.0 Draft
Effective Date: [INSERT DATE]
1. Cancellation - Subscriptions
1.1 How to Cancel

You may cancel any TMM subscription at any time. To cancel:

1.2 Effect of Cancellation

Cancellation takes effect at the end of your current billing period. You will retain full access to the product until the end of the period you have paid for. No further charges will be made after the cancellation is confirmed.

1.3 Founding Member Subscriptions

Founding member subscriptions carry a locked price that is permanently forfeited upon cancellation. If you cancel a founding member subscription, you may re-subscribe only at the current standard price, which will be higher.

2. Refund Policy
2.1 General Position

Due to the digital nature of our products and the immediate access granted upon subscription, TMM's general position is that subscriptions are non-refundable once access has been granted. However, we consider refund requests on a case-by-case basis and aim to resolve genuine issues fairly.

2.2 When Refunds May Be Granted
SituationRefund Position
You were charged in error (duplicate charge, wrong amount)Full refund of incorrect charge
Technical issue prevented access for 7 or more consecutive daysPro-rated credit or refund at TMM's discretion
You cancel within 24 hours of first subscribing and have not accessed the productFull refund at TMM's discretion
Product fundamentally does not match descriptionAssessed on a case-by-case basis
Change of mind after accessing the productNot eligible for refund
Trading losses incurred while using TMM productsNot eligible for refund (as disclosed in Risk Disclosure Statement)
2.3 One-Time Purchases

One-time purchases (such as the TMM Interactive Journal) are non-refundable once the digital product has been delivered or accessed, unless the product is fundamentally defective.

2.4 Australian Consumer Law

Nothing in this refund policy limits or excludes your rights under the Australian Consumer Law. If a product or service fails to meet a consumer guarantee under the Australian Consumer Law, you may be entitled to a remedy regardless of this policy. Contact us to discuss your specific situation.

2.5 EU Consumer Rights

EU consumers may have a 14-day right of withdrawal from digital service contracts under the Consumer Rights Directive. However, where you have expressly requested immediate access to digital content and acknowledged that the right of withdrawal is thereby waived, no withdrawal right applies. This acknowledgement is obtained at the time of purchase.

3. How to Request a Refund

To request a refund, email [SUPPORT@TRADEMANAGEMENTMASTERY.COM] with:

We will respond within 5 business days. Approved refunds are processed within 10 business days to the original payment method.

4. TMM Market - Third-Party Products

Products purchased through the TMM Market from third-party creators are subject to the refund policies of the individual creator. TMM is not responsible for refunds of third-party products, though we may assist in dispute resolution. Creator refund policies must be displayed clearly on their product listing.

Legal Review Notes

Key items: (1) Confirm the EU 14-day withdrawal right position and the required disclosure language at point of purchase. (2) Confirm the ACL consumer guarantee section is accurate and complete. (3) Consider whether the "24-hour cancellation" provision should be formalized as a policy rather than discretionary.

Post-Launch - Draft - Requires Legal Review
Community Rules
TMM Community (Circle) - Terms of Participation
Version: 1.0 Draft
Effective Date: [INSERT DATE]

Welcome to the Trade Management Mastery community. These Community Rules govern participation in all TMM community spaces, including the Circle community, any Discord or Telegram channels, and any other community platform operated by TMM. By joining and participating in the TMM Community, you agree to these rules.

1. The TMM Community Standard

TMM is a community of serious traders. Our standard is quality over quantity. We maintain a professional, respectful, and honest environment. The community exists to help members develop as traders - not to entertain, not to hype, and not to promote get-rich-quick thinking.

2. The Most Important Rule - No Financial Advice
Critical Rule

No member, moderator, or TMM team member in the community is providing financial advice. All analysis, trade calls, market commentary, indicator readings, and signals shared in the community are for educational purposes only. Do not make trading decisions based solely on what you read in the community. You are solely responsible for your own trading decisions and their outcomes.

3. Conduct Rules
3.1 Required Behaviour
3.2 Prohibited Behaviour
4. Trading Discussion Guidelines

When discussing trades or market analysis in the community:

5. Content Ownership and Licence

By posting content in the TMM Community, you:

6. Moderator Authority

TMM moderators have the authority to:

Moderator decisions are final. If you believe a moderation action was made in error, contact [SUPPORT@TRADEMANAGEMENTMASTERY.COM] to appeal.

7. Consequences of Rule Violations
Violation LevelConsequence
Minor (first offence)Content removed, verbal warning
Repeated minor violationsFormal warning, temporary posting restriction
Serious violation (spam, harassment, promotion of external services)Immediate suspension from community, review for permanent removal
Severe violation (market manipulation coordination, fraud, doxxing)Immediate permanent removal, no refund, potential referral to authorities

Removal from the TMM Community for rule violations does not entitle you to a refund of any subscription fees paid.

8. TMM Market Creators

Members who list products on TMM Market are subject to additional terms in the TMM Market Creator Agreement. Creators are responsible for ensuring their products and marketing comply with applicable laws and these community rules.

9. Disclaimer

The TMM Community provides a space for educational discussion. All content shared by community members, moderators, or TMM staff is for educational purposes only. Nothing in the community constitutes financial advice. TMM is not responsible for any trading decisions made by community members based on community content.

Legal Review Notes

Key items: (1) Confirm whether the content licence granted to TMM is appropriate and clearly worded. (2) Review rule on market manipulation - consider whether specific references to relevant criminal/civil provisions are appropriate. (3) Confirm whether Australian defamation law requires any specific provisions given the community's global reach.

Post-Launch - Draft - Requires Legal Review
End User Licence Agreement
TMM Engine (Algorithmic Bot) and TMM Pulse (Signals Service)
Version: 1.0 Draft
Effective Date: [INSERT DATE]
Applies to: TMM Engine subscribers and TMM Pulse subscribers
Important - Additional Terms

This EULA is an additional agreement that supplements the TMM Terms of Service and Risk Disclosure Statement for subscribers to TMM Engine and TMM Pulse. All terms of the general Terms of Service remain in force. In the event of conflict between this EULA and the general Terms, this EULA prevails for Engine and Pulse subscribers.

1. Definitions
TermMeaning
TMM EngineThe dual-strategy algorithmic trading bot software provided by TMM that connects to your exchange account via API
TMM PulseThe signal delivery service that sends trade signals from the TMM Engine to your Telegram account
API KeysThe API credentials you generate from your Bybit exchange account and provide to the TMM Engine to enable automated trading
Your Exchange AccountYour personal trading account on Bybit or any other supported exchange, which remains under your sole ownership and control
SignalA notification containing trade details (asset, direction, entry, stop loss, take profit, R:R, strategy type) delivered to your Telegram
Live TradingTrading with real money on your exchange account, as distinct from backtesting or paper trading
2. Nature of the Service
Critical Clarification

TMM does not manage your money. TMM does not hold your funds. TMM does not act as an investment manager, fund manager, or financial adviser. The TMM Engine is an automated trading tool that you connect to your own exchange account via API keys. You retain complete ownership and control of your exchange account and all funds within it at all times. TMM's software simply executes trades on your behalf according to its algorithm, subject to your chosen risk settings.

3. Licence Grant

Subject to your payment of the applicable subscription fee and compliance with this EULA, TMM grants you a limited, non-exclusive, non-transferable, revocable licence to:

This licence is strictly personal. You may not sublicence, share, or transfer access to any other person.

4. API Keys and Exchange Account Security
4.1 Your Responsibility

You are solely responsible for:

4.2 TMM's Access

The TMM Engine uses your API keys solely for the purpose of executing trades according to its algorithm. TMM does not use your API keys for any other purpose, does not store your API keys in plaintext, and does not have the ability to withdraw funds from your exchange account (withdrawal permissions should not be granted when configuring API keys).

4.3 Security Incident

In the event of a security incident affecting TMM systems, we will notify subscribers as soon as practicable and advise them to revoke API access. TMM accepts no liability for losses resulting from your failure to secure your API keys or exchange account.

5. Risk Settings and Configuration

The TMM Engine allows you to configure risk settings including risk percentage per trade (1%, 2%, or 3%). You acknowledge that:

6. System Availability and Interruptions

The TMM Engine requires continuous operation of TMM's servers, your internet connection, and the Bybit API to function. TMM does not guarantee uninterrupted operation. The following situations may cause trading to pause or fail:

TMM accepts no liability for trading losses, missed trades, or unintended positions resulting from system interruptions. You are responsible for monitoring your exchange account and managing any open positions manually if the bot is unavailable.

7. Updates and Changes to the Algorithm

TMM reserves the right to update, modify, or discontinue the TMM Engine algorithm at any time. We will notify subscribers of material changes to the algorithm's trading rules. You understand that:

8. Performance Expectations

TMM publishes backtest results, paper trading results, and (once live) live trading results as part of its build-in-public approach. You specifically acknowledge that:

9. No Custody, No Managed Account

TMM is not a financial institution, fund manager, or investment manager. This service does not constitute a managed account arrangement. TMM does not:

10. Termination
10.1 By You

You may terminate this EULA by cancelling your subscription. Upon cancellation, the bot will cease trading on your account at the end of your billing period. You should also revoke the API keys you granted to the TMM Engine from your Bybit account settings.

10.2 By TMM

TMM may terminate your access immediately and without refund if you: violate this EULA or the general Terms of Service; misuse the system in a way that endangers other subscribers or TMM's systems; provide false information; or engage in any fraudulent activity.

10.3 Effect of Termination

Upon termination, your licence to use the TMM Engine and Pulse services ends. You should immediately revoke all API keys you granted to the TMM Engine. Any open positions on your exchange account at the time of termination are your sole responsibility to manage.

11. Limitation of Liability for Engine and Pulse

In addition to the general limitations in the TMM Terms of Service, for Engine and Pulse subscribers specifically:

The maximum aggregate liability of TMM to you under this EULA shall not exceed the total subscription fees you paid in the three months preceding the event giving rise to the claim.

12. Acceptance

By subscribing to TMM Engine or TMM Pulse, you confirm that you have read, understood, and agree to this EULA, the TMM Terms of Service, and the Risk Disclosure Statement.

For Lawyer Review - Subscriber Acknowledgement (Optional at signup)
Subscriber Name
Date
Consider: Should subscribers be required to electronically sign/acknowledge this EULA at the point of subscribing? A checkbox acknowledgement at checkout is a common and legally effective approach.
Legal Review Notes - Most Critical Document

This is the document most in need of qualified legal review. Key items: (1) The fundamental question - does providing automated trading software that executes trades on a user's own exchange account constitute a "financial service" requiring an AFSL under the Corporations Act? This analysis is essential before any Engine subscribers are onboarded. (2) Confirm the "no managed account" framing is legally sound under Australian and relevant international law. (3) Review API key security obligations - are TMM's obligations clearly and accurately described? (4) Consider whether a checkbox acknowledgement at checkout creates a sufficient electronic signature under relevant e-commerce laws. (5) Consider whether additional regulatory disclosures are required for EU (MiCA) or UK (FCA) subscribers.

Internal Reference - TMM Team
Legal Implementation Guide
Where Everything Lives, How It All Connects, and What to Do Before Launch
Audience: Matt, Corne, Jason, Craig, Bogdan
Purpose: Practical guide to deploying these documents correctly
How to Use This Guide

This guide explains where each legal document lives on the TMM website, when it is shown to users, and what still needs to be done before these documents can be published. Work through the checklist at the bottom before taking documents to legal review.

1. The Golden Rule - Where Legal Docs Live

Legal documents do NOT go in the main navigation. Visitors should never see "Privacy Policy" sitting next to "Academy" or "Engine" in the top nav. Legal docs belong in three places only:

2. Footer Structure - Every Page

The footer on every TMM website page should have two rows below the main footer content:

Footer Row 1 - Legal Links

Privacy Policy  |  Terms of Service  |  Risk Disclosure  |  Disclaimer  |  Cookie Policy  |  Refund Policy  |  Community Rules

Footer Row 2 - Short Disclaimer (already on site)

"This is educational content only and does not constitute financial advice. All trading involves significant risk of loss. Past performance does not guarantee future results. Always do your own research and manage your own risk."

The Bot/Signals EULA is not linked from the general footer - it only appears at the Engine and Pulse checkout.

3. The Legal Hub Page

Create a dedicated page at trademanagementmastery.com/legal that lists and links to all documents. This is the URL you give to:

Section on /legal pageDocuments Listed
Pre-Purchase DocumentsPrivacy Policy, Terms of Service, Risk Disclosure Statement, General Disclaimer
Subscriber DocumentsRefund and Cancellation Policy, Community Rules, Bot and Signals EULA
Platform PoliciesCookie Policy
Version HistoryLog of all document updates with dates and summary of changes
4. Checkout and Signup Flows

This is where most platforms get into legal trouble - they publish documents but never require users to acknowledge them. A checkbox at the point of action creates a legal record that the user agreed. These checkboxes must be mandatory (cannot proceed without ticking).

Newsletter / Circle Free Tier Sign-Up
Checkbox Text

"I agree to the Privacy Policy and Terms of Service."

Indicator, Dashboard, or Signals Purchase (Edge, Intelligence, Pulse)
Checkbox Text

"I agree to the Terms of Service, Privacy Policy, and Refund Policy. I understand this is educational content only and does not constitute financial advice."

Engine Bot Purchase (Most Critical)
Two Mandatory Checkboxes

Box 1: "I have read and agree to the Terms of Service, Privacy Policy, and Refund Policy."

Box 2: "I have read and agree to the Risk Disclosure Statement and Bot and Signals EULA. I understand that trading involves risk of loss, the bot trades my own exchange account using API keys I provide, TMM does not hold my funds at any time, and past performance does not guarantee future results."

Stripe supports custom fields and checkboxes on checkout pages. Corne to action this as part of the Stripe configuration. Both checkboxes must be ticked before the purchase completes.

Community Paid Tier Upgrade (Circle)
Checkbox Text

"I agree to the Community Rules and Terms of Service. I understand that all content in the TMM Community is for educational purposes only and does not constitute financial advice."

5. Document by Document - Where It Lives
DocumentFooter LinkLegal HubCheckout CheckboxElsewhere
Privacy PolicyYesYesAll signups and purchasesAccount creation form
Terms of ServiceYesYesAll signups and purchasesAccount creation form
Risk DisclosureYesYesEngine and Pulse checkoutEngine, Pulse, and Edge product pages - visible without clicking
General DisclaimerYes - short form inline, long form linkedYesNoShort form appears on every page footer automatically
Cookie PolicyYesYesNoCookie consent banner on first visit
Refund PolicyYesYesAll purchasesPricing pages near price display
Community RulesYesYesCommunity join and paid upgradeCircle welcome post pinned at the top of the community
Bot/Signals EULANoYesEngine and Pulse checkout onlyEngine and Pulse product pages - "by subscribing you agree to the EULA" link
6. Product Page Requirements

Certain pages need legal language visible without the user having to click anything - not just in the footer. This is particularly important for the bot and signals products.

Engine Page (TMM_Engine.html)
Pulse Page (TMM_Pulse.html)
Edge Page (TMM_Edge.html)
7. Cookie Consent Banner

A cookie consent banner is required for GDPR compliance (EU users). This is a technical implementation that goes beyond just having a Cookie Policy document. The recommended approach for the TMM static HTML site:

8. Document Version Control

Every document must carry a version number and effective date. When a document is updated:

Change TypeNotification RequiredNotice Period
Typographical or formatting fixNone requiredNone
Clarification that does not change substanceWebsite notice onlyNone
Changes to user rights, refund terms, or data useEmail to affected subscribers + website notice14 days minimum
Price changesEmail to affected subscribers30 days minimum
New product-specific terms (e.g. new EULA)Email to affected subscribers + new checkbox at next login14 days minimum
9. Before Taking Documents to Legal Review

Complete all of these before the meeting with Bogdan's partner. The more you resolve, the cheaper and faster the legal review will be.

ItemOwnerStatus
Confirm the legal entity name (Cyprus company name once registered)Jason + CraigPending
Confirm governing law preference - Cyprus law, Australian law, or bothJason + Craig + Bogdan's partnerPending
Confirm all team contact emails (privacy@, legal@, support@)CornePending
Confirm the Engine bot API architecture in writing - does TMM store API keys? Where? How secured?MattPending
Confirm list of all third-party processors that handle personal data (check Privacy Policy table is complete)CornePending
Confirm whether any TMM product actively solicits users in jurisdictions where crypto trading is prohibited (e.g. USA certain states, China)TeamPending
Confirm the refund policy position - is the 24-hour discretionary refund to be formalised as policy or remain discretionary?Matt + CornePending
Confirm whether EU 14-day withdrawal right applies and how it will be handled at checkoutBogdan's partnerFor lawyer
AFSL question: Does the Engine bot subscription constitute a financial service under the Corporations Act?Bogdan's partnerFor lawyer - most critical
MiCA question: Does the Cyprus entity's role trigger any MiCA obligations for EU users?Bogdan's partnerFor lawyer
FCA question: Is the TMM website content accessible to UK users a regulated financial promotion?Bogdan's partnerFor lawyer
10. Ongoing Compliance - Who Owns What
ResponsibilityOwnerFrequency
Reviewing and updating Privacy Policy as new tools are addedCorneAny time a new third-party tool or processor is added
Monitoring ASIC guidance updates relevant to TMMJason + CraigQuarterly
Ensuring all new content (newsletters, social posts, YouTube) carries appropriate disclaimersMatt + BogdanOngoing - every piece of content
Handling privacy requests (access, deletion, correction)CorneWithin 30 days of each request
Maintaining the version log on /legal pageCorneAny time a document is updated
Annual legal review with Bogdan's partnerCorne + JasonAnnually
Monitoring for regulatory changes in key markets (Australia, EU, UK)Jason + CraigQuarterly
11. Practical Implementation Timeline
WeekTaskOwner
Week 1 (now)Send all 8 draft documents to Bogdan's partner for reviewCorne
Week 1Fill in all red placeholder fields that are known (entity name, emails, dates)Corne
Week 1Select and set up cookie consent platform (CookieYes or Cookiebot)Corne
Week 2Receive legal feedback, action revisionsCorne + Bogdan's partner
Week 2Add legal footer links to all 9 website pagesMatt (or Claude Code)
Week 2Build /legal hub page on websiteMatt (or Claude Code)
Week 2Configure Stripe checkout checkboxes for each product typeCorne
Week 3 (pre-launch)Final legal sign-off, documents published to /legal pageBogdan's partner + Corne
Launch dayConfirm all footer links resolve correctly on live GoDaddy siteMatt + Corne
Summary - The Three Non-Negotiables Before Launch

1. All 8 documents reviewed and signed off by qualified legal counsel - the AFSL question on the Engine bot is the critical unknown.

2. All documents published at /legal and linked from every page footer before any user can sign up or purchase.

3. Mandatory checkboxes at every purchase and signup flow - if a user has not acknowledged the Terms, Privacy Policy, and relevant risk disclosures, the legal protection is significantly weaker.