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TERMS OF SERVICE & PRIVACY POLICY

Last Effective Update: July 12, 2026

IMPORTANT LEGAL NOTICE: This Agreement constitutes a valid and legally binding contract between you as a User and PT Leodra International Technology (the "Company"). By downloading, accessing, or using LEODRA services, you agree to all terms and conditions in this Agreement. If you do not agree to these terms, you are not permitted to access or use LEODRA services.

A. Terms of Service

Article 1 — General Terms and Scope of Service

1.1. Legal Agreement: This Agreement constitutes a valid and legally binding contract between you as a User and PT Leodra International Technology ("Company"). By downloading, accessing, or utilizing the LEODRA platform, you acknowledge that you have read, understood, and agreed to be bound by all terms set forth in this document.

1.2. Legal Capacity: The User warrants and represents that they are of legal age of majority under applicable laws in their jurisdiction of residence and possess full legal capacity to enter into binding commercial digital service agreements.

1.3. Modifications to Terms: The Company reserves the right to update or modify the provisions of this Agreement from time to time to align with technological advancements, regulatory requirements, or operational policies. Continued use of the service following the announcement of modifications constitutes valid acceptance of such revised terms.

Article 2 — Software Classification and Financial Liability Limitation

2.1. Pure Software-as-a-Service (SaaS) Provider Status: LEODRA is a cloud-based software application functioning exclusively as an analytical trading journal, mathematical risk calculator, and portfolio performance synchronization instrument. The Company does not engage in financial banking, brokerage, investment management, fund collection, fund custody, investment advisory, or any licensed financial services activity. The Company does not maintain, control, or have access to Users' financial funds, trading accounts, or broker-held assets in any capacity.

2.2. No Financial Advice: All data, outputs, and metrics generated by the LEODRA system—including but not limited to risk-to-reward ratios, historical win probabilities, and leaderboard analytics—are strictly computational statistical representations. No part of this platform constitutes financial advice, investment recommendations, or trading solicitation by the Company.

2.3. Release from Financial Losses: The User fully acknowledges and understands that financial markets carry inherent high volatility. Any material losses, capital account drawdowns, position liquidations (stop-out or margin calls), or intangible damages incurred during trading activities are solely the User's independent responsibility. PT Leodra International Technology is expressly and unconditionally released from any and all claims, demands, or indemnification obligations regarding such trading losses.

2.4. Algorithmic Performance and Historical Simulations: Historical performance backtesting and algorithmic probability calculations do not guarantee future trading results or profits. The service is provided "as is" and "as available" strictly to facilitate the User's independent evaluation and analysis.

2.5. Technology Synchronization — Not Fund Management: The portfolio copy-synchronization feature ("Copy-Sync") is a technological instrument enabling Users to voluntarily mirror publicly available trading strategy data from other registered platform Users to their own independently maintained broker accounts. At no point does the Company or any Master Trader assume custodial, fiduciary, or management responsibility over the financial assets of any User. All decisions to activate, deactivate, or modify Copy-Sync settings are made solely by the User. Partnership commissions paid to Master Traders represent technology platform service fees, not profit-sharing from investor funds.

2.6. Internal Credits System — Not Electronic Money: Leodra Credits is an internal platform credit system used exclusively to facilitate digital service transactions within the LEODRA ecosystem. Leodra Credits is not a form of electronic money, payment instrument, or financial product issued by a licensed financial institution. Leodra Credits cannot be used outside the LEODRA platform and holds no monetary value independent of the platform's digital services.

2.7. Cloud Infrastructure & Open-Source Architecture Accountability (Safe Harbor): To deliver optimal real-time responsiveness, cross-device synchronization, and global scalability, LEODRA incorporates industry-standard Content Delivery Networks (CDN) and MIT-licensed open-source stylesheets and libraries (including Tailwind CSS, Chart.js, and Lucide Icons). The User explicitly acknowledges and agrees that any development or runtime compilation notices appearing in client-side console environments are normal operational characteristics of dynamic cloud SaaS architecture and do not impair data integrity, system security, or legal compliance. The Company operates in full compliance with valid open-source licenses and commercial web standards. PT Leodra International Technology, its Board, and Founders are unconditionally released and held harmless from any technical disputes, claims, or third-party liabilities regarding CDN rendering behaviors, third-party library execution, or client-side compilation dynamics.

Article 3 — Integrity of Use and Account Security

3.1. Exclusive Use: Registered accounts are personal and exclusive to a single individual User. Users are strictly prohibited from transferring, leasing, or authorizing external parties to access their account without prior written permission from the Company.

3.2. Prohibition of Illegal Automation: Users are strictly prohibited from deploying automated software, web scrapers, bots, or unauthorized external scripts to extract data, overburden server infrastructure (Denial of Service attacks), or reverse-engineer LEODRA's algorithmic logic.

3.3. Credential Security: Users bear sole responsibility for maintaining the confidentiality and security of their authentication credentials. All activities conducted through a registered account are deemed valid and authorized actions of the respective User.

3.4. Identity Accuracy & Verification Accountability (Zero-OTP Protocol): To deliver an efficient, seamless, and frictionless user experience, the platform enables direct self-service profile and contact number updates without requiring third-party SMS or OTP verification loops. Consequently, the User bears absolute and unconditional responsibility for ensuring the accuracy, ownership, and validity of all identity data and phone numbers inputted into the system. PT Leodra International Technology and its Founders are expressly released from any third-party claims, legal liabilities, or damages arising from incorrect data entry, typographical errors, or identity misrepresentations by the User.

3.5. Secure Self-Service Password Recovery Protocol (Cryptographic Token-Based Flow): In the interest of protecting User account security and personal data integrity in full compliance with UU Perlindungan Data Pribadi (UU No. 27 Tahun 2022) and globally recognized cybersecurity standards, the LEODRA platform employs an exclusively token-based, cryptographically secured password recovery mechanism. All password reset requests are processed exclusively through digitally signed, time-limited cryptographic tokens delivered to the User's registered email address via the Supabase Authentication infrastructure. At no point does the platform expose, transmit, or process account credentials through unprotected browser query strings, direct frontend-to-database RPC calls accessible to unauthenticated parties, or any mechanism lacking server-side session validation. Users acknowledge that the security and confidentiality of their registered email address is their sole responsibility, and that PT Leodra International Technology is unconditionally released from any and all liability arising from unauthorized access to a User's email account or any other breach of User-controlled security boundaries.

Article 4 — Subscriptions, Billing, and Fair Use Policy

4.1. Web Premium Service Access: Utilization of certain advanced features on our web platform requires a paid web subscription ("LEODRA EXTRA" / Web Plan) processed exclusively through authorized payment gateway partners on our official website. The LEODRA mobile application (distributed via Apple App Store and Google Play Store) is provided 100% free of charge and contains no in-app purchases, paid tiers, or subscription billing mechanisms.

4.2. Web Automatic Renewal: For web subscriptions, service plans automatically renew at the end of each active billing period unless the User deactivates auto-renewal in their web account billing settings at least twenty-four (24) hours prior to the expiration of the current period.

4.3. Fair Use & Refund Policy: In the spirit of mutual transparency and fair dealing, all confirmed web subscription transactions are final and non-refundable, except in cases of verifiable, permanent infrastructure failure on the part of the Company or where explicitly required by mandatory consumer protection laws. The Company remains committed to delivering optimal system reliability for all Users.

4.4. Platform & Gateway Fees (Tax Compliance): To maintain full compliance with corporate tax regulations (including non-PKP status under Indonesian tax law), any secondary administrative charges associated with web subscriptions represent commercial web platform maintenance and payment gateway processing fees rather than Value Added Tax (PPN). All billing invoices generated by the web platform are legitimate commercial software service receipts.

Article 5 — Intellectual Property Rights and Third-Party Acknowledgment (Safe Harbor)

5.1. Proprietary System Ownership: All intellectual property rights in the algorithmic logic ("LEODRA Logic"), internal business architecture, trademarks, and proprietary interface compilation are the absolute property of PT Leodra International Technology, protected under applicable copyright and trademark laws.

5.2. Third-Party Copyrights & Open-Source Acknowledgment (No Over-Claim): In adherence to global copyright compliance and integrity, PT Leodra International Technology expressly declares that it does not claim ownership over open-source software libraries, web fonts (such as Google Fonts), graphical icons (such as Lucide/Tailwind), embedded charting widgets (such as TradingView), or external market data APIs integrated within this application. All such external assets remain the copyrighted property of their respective official licensors under their designated licenses (such as MIT License, Apache 2.0, SIL Open Font, or TradingView Terms of Use). Furthermore, MetaTrader, MT4, and MT5 are registered trademarks of MetaQuotes Software Corp., and TradingView is a registered trademark of TradingView, Inc. PT Leodra International Technology operates strictly as an independent analytics software provider (SaaS) and is not affiliated with, endorsed by, or sponsored by MetaQuotes Ltd. or TradingView, Inc.

5.3. Amicable Settlement Protocol (Safe Harbor Covenant): Should any copyright holder identify visual materials or code components requiring attribution adjustments within the LEODRA ecosystem, the parties agree to resolve such matters amicably through formal written notice. The Company commits to performing necessary attribution adjustments or reviews within a reasonable timeframe without triggering litigation, financial penalties, or legal liability against the Company or its Founders.

Article 6 — Corporate Limitation of Liability and Legal Shield

6.1. Corporate Legal Shield: The User agrees that any enforcement of legal rights or obligations under this Agreement may only be directed against the corporate entity PT Leodra International Technology. The User expressly waives and releases any right to initiate civil claims, criminal charges, or arbitration proceedings against individual Founders, Owners, Board of Directors, Commissioners, or Employees regarding matters arising from the operation of this software.

6.2. Maximum Liability Cap: In the legal event that the Company is held liable by a competent judicial authority or arbitration tribunal for systemic malfunctions proven to be directly and intentionally caused by the Company, the total maximum financial liability of the Company to the User shall be strictly limited to the cumulative subscription fees paid by the User to the Company during the three (3) months immediately preceding the occurrence of such event.

6.3. Force Majeure: The Company is exempt from liability for operational disruptions or outages caused by events beyond its reasonable corporate control, including but not limited to natural disasters, massive power outages, global telecommunication network failures, governmental regulations, external cyber attacks, or infrastructure failures at partner cloud server providers.

Article 7 — Indemnification and Legal Protection

The User agrees to defend, indemnify, and hold harmless PT Leodra International Technology, its Board of Directors, Commissioners, Founders, and Employees from any third-party claims, lawsuits, or damages arising out of: (a) the User's use of the service in violation of this Agreement; (b) the User's breach of applicable tax, securities, or financial regulations; or (c) losses suffered by third-party clients or investors who relied upon analysis or screenshots of the User's trading journal.

Article 8 — Governing Law and Dispute Resolution

8.1. Legal Jurisdiction: This Agreement is governed by, construed, and enforced in accordance with the laws of the Republic of Indonesia.

8.2. Dispute Resolution: Any dispute or claim arising out of or relating to this Agreement shall first be resolved through amicable negotiation for a period of thirty (30) calendar days. If no agreement is reached, the dispute shall be resolved exclusively and finally through the Badan Arbitrase Nasional Indonesia (BANI) in Jakarta in accordance with its applicable arbitration rules, or through the competent District Court having jurisdiction over the registered legal domicile of PT Leodra International Technology.

8.3. Class-Action Waiver: The User agrees that all dispute resolutions shall be conducted on an individual basis. The User expressly waives any right to file or participate in a class-action lawsuit or representative proceeding against the Company.

B. Privacy Policy & Data Protection

PT Leodra International Technology is fully committed to safeguarding the confidentiality and privacy of your personal data. This Privacy Policy is structured in accordance with the mandate of Law Number 27 of 2022 concerning Personal Data Protection (UU PDP), standard principles of the General Data Protection Regulation (GDPR), as well as privacy guidelines of the Apple App Store and Google Play Store ecosystems. We enforce transparent data governance principles, data minimization practices, and modern encryption-based infrastructure security.

Article 1 — Data Collection Categories and Minimization

In compliance with data minimization principles, the Company only collects and processes data parameters that are functionally relevant for system operation:

  • Basic Identity Data: Strictly limited to Email Address, Display Name (Alias), and encrypted authentication tokens required for account verification.
  • Analytics and Trading Journal Data: Numerical parameters, entry prices, and trading configurations that you manually input into the application to be processed by our analytical algorithms.
  • Optical Character Recognition (OCR) Image Processing Data (On-Device Only): When utilizing the OCR text recognition feature in our Risk Calculator (powered by Google ML Kit), image processing is executed entirely locally on your device (on-device processing). No camera feeds, photos, or text data are ever transmitted to our servers or Google servers.
  • Read-Only Analytics Tokens: For optional third-party portfolio tracking (such as MetaTrader or Prop Firm accounts), the platform strictly accepts only Read-Only Investor Passwords / API Tokens. Master Trading Passwords are prohibited and rejected by the system.
  • Anonymous Technical Telemetry: Non-personal device system information (such as operating system type, screen resolution, application version, and system error logs) collected anonymously to maintain network stability and conduct technical troubleshooting (bug fixing).

Article 2 — Purpose of Processing and SaaS Data Isolation

All data processed within the LEODRA ecosystem is utilized exclusively for the purposes of:

  • Providing mathematical calculations, probability evaluations, and visual representations on the User's personal dashboard.
  • Preparing leaderboard features ("Top Analyst"), wherein the User's actual monetary nominal values are censored and converted into anonymous percentage ratios (blind percentages), ensuring that your trading capital privacy remains completely protected.
  • Monitoring server reliability, network firewall security, and preventing system manipulation or illegal cyber intrusions.

Affirmation of Financial Isolation: As a pure SaaS provider, we never request, record, or possess access to your brokerage account login credentials, are not connected to your banking accounts, and do not store physical financial asset data. The Company will never trade, lease, or sell your personal data or trading journal history to external advertisers or data brokers under any circumstances.

2.4. Read-Only Analytics Integration Protocol (Non-Custodial Safe Harbor): To enable real-time portfolio tracking and statistical verification, the platform allows Users to link third-party analytical channels (e.g., MetaTrader / Prop Firm evaluation accounts) exclusively using Read-Only Investor Tokens (Investor Passwords). The Company strictly prohibits and refuses the input of Master Trading Passwords or execution-level API keys. Read-Only tokens are utilized solely for automated read-only parsing of trade history and cannot, under any technical circumstance, execute transactions, modify orders, or access withdrawal functions. PT Leodra International Technology operates strictly as a non-custodial analytical software provider and is unconditionally released from any liability regarding external broker operations or third-party platform availability.

Article 3 — Security Standards, Encryption, and Hardware Zero-Surveillance

3.1. Infrastructure Encryption: Account passwords and session tokens are secured using industry-standard one-way cryptographic hashing methods (such as bcrypt/scrypt). All communication traffic between client applications and servers is protected by modern Transport Layer Security (TLS/SSL) encryption.

3.2. Hardware & Camera Privacy Commitment (On-Device OCR & Zero Surveillance): The Company affirms its hardware privacy isolation commitment: The LEODRA application never activates background surveillance, audio sensors, or microphone recording of any kind. Camera access is strictly requested solely when the User explicitly initiates the Optical Character Recognition (OCR) feature within the Risk Calculator (powered by Google ML Kit). All OCR image processing is executed entirely on the User's local device (on-device processing); no photos, images, or camera feeds are ever recorded, stored on our servers, or transmitted to third parties, including Google or PT Leodra International Technology.

3.3. Cyber Risk Mitigation: While the Company enforces rigorous technical and organizational security standards, the User acknowledges that no data transmission over the global internet is completely immune from cyber threats. In the event of a security incident beyond reasonable corporate control (force majeure), the Company will execute forensic emergency response protocols and issue official notifications as mandated by applicable personal data protection laws, while maintaining the corporate liability limitations set forth in Section A of this Agreement.

Article 4 — Authorized Disclosure and Cross-Border Transfer

4.1. Limited Disclosure: User data is isolated within our server ecosystem and may only be accessed by third parties under strictly regulated operational boundaries: (a) official web payment processing partners solely for web subscription status verification; (b) certified global cloud server infrastructure providers (such as AWS, Google Cloud, or Supabase) under binding Data Processing Agreements; or (c) when strictly mandated by a valid and binding court order from a competent jurisdiction.

4.2. Cross-Border Data Transfer: To ensure server availability and disaster recovery, database backups may be processed or stored in data centers located outside the User's domestic jurisdiction. The Company ensures that such cross-border data transfers are encrypted via TLS/SSL protocols and governed by privacy protection standards equivalent to data protection laws in the Republic of Indonesia.

Article 5 — Data Subject Rights and Permanent Account Deletion (Right to Erasure)

5.1. Control Over Personal Data: In accordance with applicable data protection laws, the User maintains full rights to access, update, correct, or restrict the processing of their account identity profile information through the Settings menu within the application.

5.2. Permanent Account Deletion: The User has the right to execute self-service account deletion via the Account Deletion (Eradication) feature available on the application interface. Executing this protocol will permanently erase all identity profiles, analytical journal history, and account credentials from our active database. This deletion process is final and irreversible. Limited administrative billing records may be retained in encrypted cold storage solely to satisfy mandatory legal compliance and state tax audit obligations.

C. Apple App Store EULA (iOS Compliance)

If you download, install, or access the LEODRA application via the Apple App Store for iOS ecosystem devices, you are required to comply with the Minimum Terms of Developer's End-User License Agreement. These terms are binding as a supplement to the Terms of Service above:

1. Acknowledgment & Scope of License

You and PT Leodra International Technology acknowledge that this license agreement is concluded solely between you and the Company, and not with Apple Inc. ("Apple"). The Company is solely responsible for the Licensed Application and the content thereof. The license granted is limited to a non-transferable right to use the application on Apple-branded products that you own or control as permitted by the Usage Rules set forth in the Apple Media Services Terms and Conditions. Furthermore, you acknowledge that the LEODRA iOS application is distributed 100% free of charge and contains no Apple App Store In-App Purchases or subscription billing mechanisms.

2. Maintenance & Support

The Company is solely responsible for providing any maintenance and support services with respect to the application as required under applicable law. You acknowledge and agree that Apple has no obligation whatsoever to furnish any maintenance and support services with respect to the Application.

3. Warranty & Product Claims

In the event of any failure of the application to conform to any applicable legal warranty, you may notify Apple, and Apple (in accordance with its platform policies) may refund the purchase price for the application to you. To the maximum extent permitted by applicable law, Apple will have no other warranty obligation whatsoever with respect to the application. The Company (not Apple) is responsible for addressing, investigating, defending, and settling any third-party claims relating to the application, including consumer protection claims or intellectual property infringement claims (subject to the Safe Harbor protocol in Article 5 of Section A).

4. Third-Party Beneficiary

You and the Company hereby acknowledge and agree that Apple Inc. and its subsidiaries are Third-Party Beneficiaries of this EULA agreement. Upon your acceptance of the terms and conditions of this document, Apple will have the legal standing (locus standi) and right to enforce this EULA against you directly as a third-party beneficiary.

D. Google Play Store DDA (Android Compliance)

If you download, access, or utilize the LEODRA application via the Google Play Store for Android operating system devices, you are subject to the Google Play Developer Program Policies and the Google Developer Distribution Agreement (DDA). The following terms constitute an inseparable part of this Agreement:

1. Platform Severability and Google Liability Disclaimer

You acknowledge that this binding agreement is concluded exclusively between you and PT Leodra International Technology, and not with Google LLC or its affiliates ("Google"). PT Leodra International Technology acts as an independent developer entity maintaining full operational control over the LEODRA software. Google is released from any maintenance obligations, technical support, or indemnification liability arising from the utilization of this application.

2. 100% Free Mobile Application & Zero In-App Billing

The LEODRA mobile application distributed within the Android ecosystem (Google Play Store) is provided 100% free of charge and contains zero in-app purchases (IAP), paywalls, or subscription billing mechanisms. All advanced analytical features within the mobile application are fully accessible without any financial transactions through Google Play In-App Billing. Any optional paid subscription features ("LEODRA EXTRA" / Web Plan) exist strictly and exclusively on the separate web platform and are never billed through Google Play Store.

3. Affirmation of SaaS Classification Across All Distribution Channels

Whether distributed via Apple App Store, Google Play Store, or official web portals, the User confirms their agreement that PT Leodra International Technology operates purely as an analytical computing software provider. All financial trading decisions remain the User's independent responsibility, and corporate legal protections as well as Founder personal immunity (Founder Shield) apply consistently across all application distribution platforms.

Severability: If any provision or clause of this Agreement is held to be invalid, void, or unenforceable by a court or data protection authority of competent jurisdiction, such invalidity shall apply only to the specific provision involved (severed independently) and shall not invalidate or impair the validity and enforceability of any other legal protection provisions herein, which shall remain in full force and effect.

Entire Agreement: These Terms of Service, together with the Privacy Policy and attached distribution platform EULAs, constitute the entire legal agreement between the User and the Company, superseding all prior written or oral agreements, communications, or representations to the contrary.