Risk Disclosure

1.About this disclosure

This disclosure explains the main risks of using the esports prediction markets and perpetual futures offered by 3-102-066254 S.R.L., trading as Subtick Markets (“Subtick”). It does not describe every risk. Read it together with our Terms of Service, which use the same terms.

If you do not understand these products or their risks, do not trade.

2.You can lose all the funds you commit

Every trade can lose money. You can lose all the funds you commit to an order or a position, and you can lose them quickly. Past results, including your own, do not predict future results.

3.Conflicts of interest

• Subtick is the market maker in every prediction market and the counterparty to every perpetual futures position. When you win, we lose, so our interests are opposed to yours.
• Indexes are currently calculated by a Subtick partner, which may also be the partner through which you access the Services. That partner operates a CS2 item marketplace whose prices may be included in an index, and it earns revenue from activity on that marketplace. It may therefore have interests that conflict with yours.
• We pay partners fees under our commercial arrangements with them.
• We have controls to manage these conflicts, including rules on index methodology and a ban on trading by staff of Subtick, its partners and the index provider, but they cannot remove the conflicts entirely.

4.Prediction markets: pricing and liquidity

• Prices come from Subtick’s market making and from other users’ orders. They are not an official probability, and they can move fast, especially during live play.
• Subtick is the market maker and trades for its own account, so its interests can be opposed to yours.
• The gap between buying and selling prices, and any fees, mean the price must move in your favour before you make a profit.
• Liquidity can be limited. You may not be able to sell when you want, at the price you want, or at all, for example near the end of an event or during a suspension. You may have to hold a contract until it settles.
• Because Subtick is your counterparty, we may limit the size of your orders or refuse them, including if you have traded successfully in the past.

5.Suspension, voiding and resettlement

• Markets can be suspended at any time, for example during live play or when data is unreliable. While a market is suspended you may not be able to trade or exit.
• Markets or trades can be voided, for example if an event is cancelled, postponed or played in a different format, or if a data error affected them. Voiding reverses trades, including trades that were in profit.
• Settlements can be corrected after a late or changed result or a data error. A resettlement can reduce or reverse an amount already paid to you, and you will then have to return it.
• Trades made at an obviously wrong price can be cancelled or adjusted.

6.Esports events and data

• Esports events can be cancelled, delayed, interrupted or replayed. Teams can change line-ups, forfeit or be disqualified, and technical problems such as server issues, pauses and remakes can affect results.
• Events can be affected by cheating or match fixing.
• Results and live data come from third-party feeds and event organisers. They can be late or wrong, and can be changed after the event.
• During live play, other people may receive information before you do, and prices may lag behind the action.

7.Perpetual futures: leverage

Leverage lets you open a position larger than the margin you commit. It magnifies gains and losses alike.

For example, at 10 times leverage, a 10% move in the index against you can wipe out all your margin, before fees and funding. At higher leverage, a smaller move is enough.

8.Perpetual futures: liquidation

• If losses take your margin below the maintenance level, your position can be liquidated automatically and without notice, in whole or in part. You can lose all the margin committed to it, and liquidation fees may apply.
• In fast or thin markets, or when an index jumps, a position can go from safe to liquidated very quickly, and the closing price can be worse than you expect.
• You may not be able to act in time, for example during an outage, a suspension, or while you are away from the app.
• Margin and liquidation are calculated using the mark price shown in the App, which can differ from the last traded price and from prices you see elsewhere.
• To manage our own risk as counterparty, we may reduce or close positions, or allow only the closing of positions in a market, even if your position has not reached liquidation. This can happen when markets move fast.

9.Perpetual futures: funding

Positions may pay or receive funding at the rates and intervals shown in the app. Funding rates change and can be large. Paying funding reduces the value of your position over time and can push it towards liquidation, even if the index does not move.

10.Indexes and the oracle

• Perpetual futures follow indexes calculated by an index provider. Indexes are currently calculated by a Subtick partner (see section 3). The index uses data from that partner and from third-party sources.
• The index provider does not act for you, owes you no duty and does not guarantee any index. You cannot claim against it for any index value.
• The data behind an index can be stale, wrong, incomplete or manipulated. An index can differ from prices you see elsewhere.
• When an index is stale or unreliable, trading may be paused, and you may not be able to open or close positions. Trades and liquidations affected by an index error may be corrected under our Terms, but not every error will be caught.
• The index provider can change an index’s methodology, sources or components, and Subtick can change the index provider. Such changes can move the index and the value of your position.

11.CS2 skin markets

• CS2 skin indexes are based on the prices of in-game items on marketplaces operated by Subtick partners and other third parties. These markets are small compared with traditional financial markets. Liquidity can be thin, a few large holders can move prices, and prices can be manipulated.
• Skin prices depend on decisions by the game’s publisher and by marketplaces, such as changes to trading rules, trade holds, item supply, game updates or action against marketplaces. These can move prices sharply and without warning.
• Marketplaces can go offline, change their fees or rules, or close, which affects the data behind an index.
• The activity, fees and rules of the marketplaces whose data is used, including any marketplace operated by a Subtick partner, can affect an index.

12.Crypto assets

• Crypto prices are highly volatile. They trade around the clock and can move sharply at any time, including when you are not watching.
• You fund your balance with crypto assets. We credit deposits in US dollars at the rate shown in the App, and we pay withdrawals in crypto assets at the rate shown in the App before you confirm. Price changes between when you buy, deposit and withdraw crypto assets can affect what you receive.
• We hold the assets that back your balance as US dollar stablecoins. Stablecoins can lose their peg, and their issuers can freeze them, fail or face action by authorities, which could affect our ability to pay you.
• Blockchain networks can be congested or fail, which can delay deposits and withdrawals. Blockchain transactions cannot be reversed, and crypto assets sent to the wrong address or on the wrong network may be lost for good.
• On-ramp providers are third parties. If one fails, delays or refuses your purchase, Subtick may not be able to help.

13.Technology and outages

The Services depend on software, networks, data feeds, hosting providers, blockchain networks and partners’ websites. Any of these can fail, slow down or be attacked, and software can contain bugs. You may be unable to place, cancel or close orders, or to deposit or withdraw, orders may be delayed or executed at different prices, and positions may be liquidated while you cannot act.

14.Access through partners

• If you use the Services through a partner and the partner has an outage, restricts or closes your partner account, or stops working with Subtick, you may be unable to use the Services through that partner.
• Your balance is held by Subtick, not by the partner, and is separate from any balance you hold with the partner. You cannot move funds between them.
• The partner does not guarantee any amount Subtick owes you and is not responsible for Subtick’s obligations. Your claims about the Services are against Subtick only.

15.How Subtick holds your funds

Subtick holds your balance and committed funds itself, as US dollar stablecoins in wallets it controls, which may hold the assets of many customers together. Subtick is not a bank. Your balance and committed funds are not bank deposits and are not protected by deposit insurance or an investor compensation scheme. We do not hold your balance or committed funds on trust for you. If Subtick became insolvent, or its wallets were hacked or otherwise compromised, you could lose some or all of your balance and committed funds.

16.Withdrawals

• You must trade the funds you deposit before you can withdraw them (the trading requirement in our Terms of Service). Until you have traded them, you cannot withdraw the part of your balance that equals your untraded deposits.
• We may hold, delay or refuse a withdrawal while we carry out identity, anti-money laundering, sanctions or fraud checks. You may not be able to withdraw when you want.
• Withdrawals are paid in crypto assets to the address you give us and cannot be reversed. Minimum amounts and fees apply.

17.Legal and regulatory change

• Laws on prediction markets, derivatives, gambling and crypto vary between countries and change over time. A change could force us to restrict access, change or close markets or products, or stop serving a country, sometimes at short notice. Your positions could then be closed at a time you did not choose.
• Subtick is not a bank, broker, investment firm, exchange or payment institution, and the Services are not offered as regulated financial products.
• Authorities in your country may treat these products as gambling, as financial derivatives, or as both. Using them may be unlawful where you are, and you could face penalties.
• Depending on where you are, the Services may not be regulated in the same way as financial products or gambling, and you may not have the protections that those rules give. Any licence we hold may not give you the protections of the rules in your own country.
• You are responsible for making sure your use of the Services is lawful where you are. Tax rules for these products can be unclear and can change.

18.No advice

Subtick does not give investment, financial, legal or tax advice. Prices, indexes, charts and other information in the app are not recommendations. We act for our own account and owe you no fiduciary duty.

19.Only trade what you can afford to lose

Only commit money you can afford to lose entirely without affecting your living costs or obligations. Do not borrow to trade, and do not try to win back losses by trading more.

20.Responsible trading

Trading can become a problem. Warning signs include trading more than you planned, chasing losses, using money meant for bills, hiding your trading from others, or feeling anxious or stressed about it.

• You can ask support@subtickmarkets.com to set limits on your trading, or to exclude you from the Services for a period. During a self-exclusion you can still close positions, receive settlements and withdraw your balance. See our Terms of Service.
• Take regular breaks, and decide in advance how much you are willing to lose.
• If you think you have a problem, stop trading and seek help from a local support organisation.
• A self-exclusion with Subtick does not cover a partner’s own products. Contact the partner if you want to exclude yourself there too.
• Free, confidential support is available internationally from Gambling Therapy (gamblingtherapy.org), and from local support organisations in many countries.

21.Contact us

For questions about these risks, trading limits or self-exclusion, contact support@subtickmarkets.com.