Disclaimer

DISCLAIMER

PropaTrade Education Private Limited

CIN: U85500AP2026PTC125374

Last Updated: July 23, 2026

Effective Date: July 23, 2026

COMPREHENSIVE DISCLAIMER

This Disclaimer ("Disclaimer") is issued by PropaTrade Education Private Limited, a company incorporated under the Companies Act, 2013, bearing CIN: U85500AP2026PTC125374, having its registered office at Flat No 501, Sai Krupa Residency, Tirupati, Andhra Pradesh 517501, India ("PropaTrade," "Company," "we," "us," or "our").

This Disclaimer applies to all individuals who access the PropaTrade website, the Udaan simulated trading platform, or participate in any PropaTrade program, whether as applicants, Research Contractors, Consultants, or visitors.

BY ACCESSING OR USING THE PLATFORM, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO THIS DISCLAIMER.

1. SIMULATED TRADING DISCLAIMER

1.1 ALL trading activity on the Udaan platform is conducted in a 100% simulated and virtual environment. No real money is traded, invested, or at risk at any time.

1.2 The "Allocated Research Capital" or "Virtual Capital" displayed on your account is entirely virtual and fictitious. It is a notional capital allocation used solely for the purposes of education, skill evaluation, and simulated trading research. It does NOT represent real funds, a real trading account, a managed fund, or a deposit.

1.3 Simulated trading results are hypothetical. They do not represent actual trading and may not reflect the impact of actual market conditions, including but not limited to liquidity constraints, slippage, order execution delays, and market impact.

1.4 Pursuant to U.S. CFTC Rule 4.41 (cited for informational purposes): Hypothetical or simulated performance results have certain inherent limitations. Unlike an actual performance record, simulated results do not represent actual trading. Since trades have not been executed, results may have under-or-over compensated for the impact of certain market factors such as lack of liquidity. Simulated trading programmes are also subject to the fact that they are designed with the benefit of hindsight.

1.5 PropaTrade does NOT hold, manage, pool, or invest any Contractor funds. Commitment Fees are contractor onboarding and training fees for access to the Evaluation and platform infrastructure, not investments, deposits, or margin.

2. INDEPENDENT CONTRACTOR RELATIONSHIP

2.1 PropaTrade engages individuals as independent contractors ("Research Contractors" or "Contractors") under the Indian Contract Act, 1872. Contractors are NOT employees, consumers, customers, subscribers, or agents of PropaTrade.

2.2 The Consumer Protection Act, 2019 does not apply to the engagement between PropaTrade and its Contractors. The Commitment Fee is a contractor onboarding fee, not a consumer product purchase price or subscription.

2.3 Research Stipends are performance-based professional fees for independent contractor services, classified as "Fees for Professional Services" under the Income Tax Act, 1961, subject to TDS under Section 194J. They are NOT salary, wages, employment income, investment returns, guaranteed payments, or any form of consumer entitlement.

3. NO INVESTMENT ADVICE — SEBI DISCLAIMER

3.1 PropaTrade is NOT registered with the Securities and Exchange Board of India (SEBI) in any capacity whatsoever, including but not limited to:

(a) Stock Broker (under SEBI (Stock Brokers) Regulations, 1992);

(b) Investment Adviser (under SEBI (Investment Advisers) Regulations, 2013);

(d) Portfolio Manager (under SEBI (Portfolio Managers) Regulations, 2020);

(e) Depository Participant;

(f) Merchant Banker;

(g) Alternative Investment Fund;

(h) Any other intermediary registered with SEBI.

3.2 PropaTrade does NOT provide:

(a) Investment advice or recommendations;

(b) Stock tips or trading signals for real-money trading;

(d) Direct market access to BSE, NSE, or any other stock exchange;

(e) Demat account or trading account services;

(f) Portfolio management or asset management services;

(g) Any service that requires SEBI registration.

3.3 All information, charts, analyses, educational content, and trading-related data shared on the Platform are intended solely for educational purposes within the simulated environment and shall NOT be interpreted as investment advice, stock recommendations, or financial guidance.

3.4 Contractors and visitors are strongly advised to consult with a qualified, SEBI-registered financial advisor before making any real investment or trading decisions. PropaTrade is not responsible for any real trading decisions made by any person based on their experience on the Udaan platform.

3.5 In accordance with SEBI Circulars and guidelines:

(a) Always deal with SEBI-registered intermediaries;

(b) Verify the SEBI registration of any entity offering investment advice;

(d) Do not share login credentials of your real trading or demat accounts with anyone.

4. PAST PERFORMANCE DISCLAIMER

4.1 Any testimonials, performance figures, trading results, or success stories displayed on the Platform, social media, or marketing materials represent past performance in a simulated environment and are provided for illustrative purposes only.

4.2 Past performance, whether simulated or actual, is NOT indicative of future results. Financial markets are inherently unpredictable, and no strategy, methodology, or trading approach guarantees future profitability.

4.3 Payout certificates, performance metrics, and trading-related information displayed on the Platform are for illustrative purposes only and may not be representative of all Contractors' experiences.

5. RISK DISCLOSURE (EDUCATIONAL CONTEXT)

5.1 While trading on the Udaan platform is simulated and carries no real financial risk, Contractors should be aware that:

(a) Real trading in financial instruments, including equities, futures, and options, carries a high level of risk and may not be suitable for all investors;

(b) 9 out of 10 individual traders in the equity Futures and Options (F&O) segment incurred net losses, as per the SEBI study dated 25 January 2023;

(c) The skills and behaviours developed during simulated trading may not translate directly to success in real-money trading;

(d) Simulated environments may differ from real markets in terms of execution, liquidity, slippage, and market impact.

5.2 Contractors should not construe their simulated trading performance as an indication of their ability to trade profitably in real markets.

6. NO GUARANTEE OF CONSULTANT ACCOUNT OR STIPENDS

6.1 PropaTrade does NOT guarantee:

(a) That any Contractor will pass any Evaluation phase;

(b) That any Contractor will receive an invitation to a Consultant Account;

(d) Any specific level of income, return, or financial benefit;

(e) Any specific trading outcome or skill acquisition;

(f) That Stipend Share percentages will remain unchanged — percentages are subject to modification at PropaTrade's sole discretion;

(g) That passing the Evaluation will result in a Consultant Account invitation or eligibility for Research Stipends.

6.2 Research Stipends are performance-based professional fees contingent upon PropaTrade's operational and financial capacity and the Contractor's adherence to all Terms, Trading Rules, and applicable policies. Research Stipends are NOT guaranteed income, NOT salary, NOT employment income, NOT investment returns, and NOT real trading profits.

6.3 Stipend Share tiers:

Standard Program: 30% / 50% / 70%

Boost Program: 50% / 70% / 85%

These represent the rates in effect as at the date of this Disclaimer and are subject to change at PropaTrade's sole discretion with prospective effect.

7. MARGIN AND REPLICABILITY DISCLAIMER

7.1 The Udaan platform uses simplified margin calculations that apply the same margin requirements for option buying and option selling. This is a deliberate simplification for training and research purposes.

7.2 Real-world brokerage margin requirements differ significantly from those used on the Udaan platform. Real brokers apply different margin structures, including SPAN margin, Exposure margin, and broker-specific policies. Margin requirements at real brokers may be substantially higher, particularly for option selling positions.

7.3 PropaTrade makes no guarantee of real-world replicability. Strategies developed on the Udaan platform may require significant adjustments to be viable in real market conditions, or may not be viable at all.

8. BSE DATA DISCLAIMER

8.1 The Platform utilises market data sourced from or based on data from the Bombay Stock Exchange (BSE). Such data is provided for the purposes of the simulated trading environment only.

8.2 PropaTrade does NOT guarantee the accuracy, completeness, or timeliness of BSE data displayed on the Platform. Simulated prices may differ from actual market prices due to data feed delays, technical limitations, or other factors.

8.3 BSE data is the intellectual property of BSE and is used under applicable terms. Contractors shall not reproduce, redistribute, or commercially exploit BSE data obtained through the Platform.

8.4 Neither BSE nor any of its affiliates shall be liable for any loss or damage arising from the use of BSE data on the Platform.

9. THIRD-PARTY CONTENT DISCLAIMER

9.1 The Platform may contain links to, or content from, third-party websites, services, or providers. PropaTrade does not endorse, verify, or assume responsibility for the accuracy, reliability, or content of any third-party material.

9.2 Any reliance on third-party content accessed through the Platform is at your own risk.

10. TECHNICAL DISCLAIMER

10.1 Platform Availability: PropaTrade does not warrant uninterrupted, error-free, or continuous availability of the Udaan platform. Service interruptions may occur due to maintenance, technical issues, force majeure, or factors beyond PropaTrade's control.

10.2 Data Accuracy: While we strive for accuracy, PropaTrade does not guarantee the accuracy, completeness, or real-time nature of any data, prices, charts, or information displayed on the Platform.

10.3 Technical Requirements: It is the Contractor's responsibility to ensure that their hardware, software, internet connection, and technical setup meet the requirements for using the Platform.

10.4 Trading Hours: Simulated trading on the Udaan platform operates during prescribed hours (9:20 AM to 3:25 PM IST for BSE/NSE segments). Availability outside these hours is not guaranteed and may be limited.

11. INTELLECTUAL PROPERTY

11.1 The Udaan platform technology is operated by PropaTrade under license from a third-party technology provider. The underlying software, algorithms, source code, and technical infrastructure remain the intellectual property of their respective owners.

11.2 PropaTrade owns its brand, trademarks, evaluation methodology, training content, business processes, and all research data and trading data generated by Contractors through use of the Platform.

12. FOREX AND CRYPTOCURRENCY EXCLUSION

12.1 Forex: PropaTrade does NOT offer, facilitate, or enable trading in foreign exchange (forex), currency derivatives, or offshore forex instruments. Indian residents are subject to restrictions on forex trading under the Foreign Exchange Management Act, 1999 (FEMA) and relevant RBI circulars.

12.2 Cryptocurrency: PropaTrade does NOT offer, facilitate, or deal in cryptocurrency, virtual digital assets (as defined under the Income Tax Act, 1961), or blockchain-based tokens. PropaTrade does not accept payment in cryptocurrency.

13. TAX LIABILITY DISCLAIMER

13.1 Contractors are solely responsible for all tax obligations arising from their engagement with PropaTrade, including but not limited to:

(a) Income tax on Research Stipends (TDS shall be deducted at 10% under Section 194J, or 20% if PAN is not provided);

(b) Goods and Services Tax (GST), where applicable;

(d) Filing of income tax returns and payment of advance tax/self-assessment tax.

13.2 Research Stipends are professional fees, NOT salary or employment income. Contractors must declare Research Stipends as income from profession/business under the Income Tax Act, 1961. PropaTrade shall deduct TDS and issue TDS certificates (Form 16A). PropaTrade does not provide tax advice.

13.3 Contractors are advised to consult their own qualified tax advisors.

14. LIMITATION OF LIABILITY

14.1 To the maximum extent permitted by applicable law, PropaTrade's total aggregate liability to any Contractor for any and all claims arising out of or in connection with the Platform, the SPRSP, or the contractor engagement shall not exceed the lesser of:

(a) The total fees actually paid by the Contractor to PropaTrade in the six (6) months immediately preceding the event giving rise to the claim; or

(b) INR 10,000 (Indian Rupees Ten Thousand).

14.2 PropaTrade, its directors, officers, employees, affiliates, and third-party technology providers shall not be liable for any indirect, incidental, special, consequential, punitive, or exemplary damages arising out of or in connection with the use of the Platform, reliance on information provided thereon, or any trading or investment decisions made based on experience on the Udaan platform.

15. SEBI CIRCULAR COMPLIANCE STATEMENT

15.1 PropaTrade is aware of and cognisant of SEBI's regulatory framework. In particular:

(a) PropaTrade operates a trading education, simulation, and research platform. All trading is conducted in a simulated/virtual environment;

(b) Research Stipends are structured as professional fees for independent contractor services in a simulated environment. They are NOT investment returns, real trading profits, or salary;

(d) PropaTrade does not facilitate real trading, provide direct market access, or act as an intermediary;

(e) PropaTrade is NOT a SEBI-registered Stock Broker, Investment Adviser, Research Analyst, Portfolio Manager, or any other SEBI-regulated intermediary.

16. MANDATORY DISCLAIMER FOR PUBLIC MATERIALS

16.1 All public communications about PropaTrade, including social media posts, videos, articles, testimonials, and marketing materials, must include the following disclaimer:

"Trading involves risk. Results shown are from a simulated environment and do not guarantee similar outcomes. Individual results may vary significantly."

17. CONTACT INFORMATION

For any queries regarding this Disclaimer, please contact:

Grievance Officer: Sai Kalyan GP, Director

Email: [email protected]

Address: PropaTrade Education Private Limited, Flat No 501, Sai Krupa Residency, Tirupati, Andhra Pradesh 517501, India

PropaTrade Education Private Limited

CIN: U85500AP2026PTC125374 | GSTIN: 37AALCP3285R1ZI

Registered Office: Flat No 501, Sai Krupa Residency, Tirupati, Andhra Pradesh 517501, India

Trading involves risk. Results shown are from a simulated environment and do not guarantee similar outcomes. Individual results may vary significantly.