FormationFX Terms of Service

Version: Beta 0.3 Final — Amendment 3 (OSA prohibited-content + mandatory reporting) | Date: 20 June 2026

Plain English summary: FormationFX is a football-themed paper-trading simulation game. It is not real investing — no real money changes hands, ever. Your coins and XP only exist inside the app. The leagues and competitions are for fun, not for cash prizes. This document sets the rules for using the app during the beta period.

Who We Are and What FormationFX Is
The Beta Programme
Virtual Currency and Rewards
Competitions, Leagues, and Leaderboards
User Conduct and Prohibited Use
Intellectual Property
Disclaimers and Limitation of Liability
Privacy
Changes to These Terms
Termination
Governing Law and Jurisdiction
Contact
Simulated Teams
Order Transmission Policy (including §14.15 Alpaca Connect Authorisation)

1. Who We Are and What FormationFX Is

1.1 FormationFX is operated by Matthew Hall, trading as FormationFX (sole trader), England and Wales.

1.2 FormationFX is a paper-trading simulation application built for educational and entertainment purposes. It uses real-world football and financial market data to simulate investment decisions. At no point does FormationFX involve real money, real investments, or real financial instruments of any kind.

1.3 NOT financial advice. Nothing within FormationFX — including squad picks, market data, price movements, leaderboard positions, or any in-app commentary — constitutes financial advice, investment advice, or a recommendation to buy or sell any security. FormationFX is a game.

1.4 FCA disclaimer. FormationFX is not currently authorised by the Financial Conduct Authority. The simulation features within FormationFX do not require FCA authorisation because no real money or regulated financial instruments are involved. You should seek independent financial advice from a suitably qualified, FCA-authorised adviser before making any real investment decisions. Where live trading is activated, the applicable regulatory authorisation position will be disclosed separately at the point of activation. Until activation, FormationFX operates exclusively in paper-trading mode and is not regulated by the FCA.

1.5 Eligibility. FormationFX is intended exclusively for users aged 18 or over who are resident in the United Kingdom or European Economic Area. By creating an account you warrant that (a) you are at least 18 years old, (b) you are resident in the UK or EEA, and (c) the personal information you provide at signup, including your date of birth, is accurate. We may suspend or terminate any account on credible discovery that this warranty was incorrect at signup, and may delete data associated with that account in accordance with our Privacy Policy.

2. The Beta Programme

Plain English: You've been invited to try an early version of the app. It's not finished. Things will break. We may shut it down with reasonable notice.

2.1 Invitation only. The FormationFX beta is a closed programme. Access is by invitation only. You may not share your invite link or credentials with any other person.

2.2 Early-access nature. The beta version is not a finished product. Features may be added, removed, or changed at any time. Data (including XP, coins, badges, and squad history) may be reset during the beta period.

2.3 Kill-gate. FormationFX reserves the right to terminate the beta programme or revoke any user's access at any time, with at least 7 days' written notice by email except where immediate termination is required to protect the integrity of the programme or comply with legal obligations.

2.4 Feedback. By participating in the beta, you agree to provide honest feedback on your experience. You grant FormationFX a non-exclusive, royalty-free licence to use your written feedback for product development purposes.

2.5 Recordings and screenshots. FormationFX may record or screenshot in-app sessions for internal product development and investor demonstration purposes. We will obtain your separate written consent before using any recording or screenshot that shows your personal identity or communications.

3. Virtual Currency and Rewards

Plain English: Your coins are game tokens. They are not money. You cannot cash them out, transfer them, or trade them for anything of real value.

3.1 Virtual only. All in-app currency (coins), experience points (XP), badges, and achievements are virtual items that exist solely within FormationFX. They are provided for entertainment and game-progression purposes only.

3.2 No monetary value. Coins, XP, badges, and achievements:

have no monetary value, market value, or cash equivalent;
cannot be redeemed for real money, gift cards, or any item of monetary value;
cannot be transferred, sold, gifted, or exchanged with any other user or third party;
are non-negotiable and non-refundable;
flow in one direction only — they are earned within the app and consumed within the app.

3.3 No entitlement. FormationFX makes no representations about the permanence of your coin balance, XP, or badge records. Virtual items may be modified, reset, or removed during the beta period without compensation.

4. Competitions, Leagues, and Leaderboards

Plain English: The leagues are for bragging rights only. There are no cash prizes. Ever.

4.1 Engagement only. Leagues, weekly competitions, head-to-head matchups, and leaderboards are scored for entertainment and engagement purposes only.

4.2 No prizes. FormationFX does not award cash, monetary prizes, gift cards, vouchers, or any item of monetary value in connection with any league, competition, or leaderboard position, during the beta period or otherwise (unless a separate, clearly labelled promotion is announced with its own terms).

4.3 No gambling. FormationFX is not a gambling service. No entry fee is charged. No prize pot exists. The skill-based simulation format and zero-prize structure are maintained by design to ensure FormationFX does not require a Gambling Commission licence.

5. User Conduct and Prohibited Use

Plain English: Play fair. Don't cheat or abuse the system.

5.1 Permitted use. You may use FormationFX for personal, non-commercial entertainment and education purposes only.

5.2 Prohibited conduct. You must not:

(a) Multi-account. Create more than one account to farm coin rewards, XP, or streak bonuses. Detected duplicate accounts will be suspended without notice.
(b) Automated access. Use bots, scripts, or automated tools to interact with FormationFX.
(c) Scraping. Systematically extract data from FormationFX by any automated means.
(d) Market-manipulation simulation abuse. Use the simulation in a manner designed to test or develop real market-manipulation strategies, or use FormationFX data to inform real investment decisions in a way that could constitute market abuse under UK law.
(e) Impersonation. Impersonate any other user, FormationFX staff, or any real person.
(f) Reverse engineering. Decompile, disassemble, or reverse-engineer any part of the FormationFX application.
(g) Harmful content. Post, transmit, or upload any content that is unlawful, offensive, defamatory, or harmful.

5.3 Consequences. Breach of Section 5 may result in immediate account suspension or termination, without notice and without refund of any beta incentive.

5.4 Prohibited Content and Mandatory Reporting. You must not use FormationFX to share, upload, store, or distribute:

child sexual abuse material (CSAM) or any content that sexually exploits or abuses minors; or
content that promotes, glorifies, solicits, or facilitates terrorism or terrorist activity.

Such conduct is a criminal offence under UK law (Online Safety Act 2023, s.67; Terrorism Act 2000, s.19). We will immediately refer any such reports to the appropriate law enforcement authorities (IWF, CEOP, CTIRU/NCA) and apply a legal hold to the relevant account.

If you encounter content of this nature on FormationFX, please report it immediately to [email protected].

6. Intellectual Property

6.1 All FormationFX content, including the application, visual design, copy, brand identity, and data structures, is owned by Matthew Hall trading as FormationFX or licensed to FormationFX by third parties.

6.2 You are granted a limited, non-exclusive, non-transferable licence to use FormationFX for personal purposes in accordance with these Terms. No other rights are granted.

6.3 Football club names, crests, player names, and statistical data are used under licence or fair use for simulation purposes. FormationFX claims no ownership over third-party intellectual property.

7. Disclaimers and Limitation of Liability

Plain English: FormationFX is a beta — it may break. We are not liable for losses arising from using the app, because no real money is involved and the app is provided free of charge during beta.

7.1 As-is. FormationFX is provided "as is" and "as available" without warranty of any kind, express or implied, including but not limited to merchantability, fitness for a particular purpose, or uninterrupted availability.

7.2 No investment loss. Because FormationFX involves no real money, you cannot suffer financial loss through the app. FormationFX accepts no liability for any real-world financial decisions influenced by in-app simulation results.

7.3 Limitation. To the fullest extent permitted by applicable law, FormationFX's total liability to you for any claim arising out of or relating to these Terms or your use of the application shall be limited to £0 (the amount paid by you during the beta period, which is nil).

7.4 Exclusions. Nothing in these Terms excludes or limits liability for death or personal injury caused by negligence, fraud or fraudulent misrepresentation, or any other liability that cannot be excluded by law.

8. Privacy

Your use of FormationFX is subject to our Privacy Policy, which is incorporated into these Terms by reference. Please read the Privacy Policy before using the app.

9. Changes to These Terms

9.1 We may update these Terms at any time. Where the changes are material, we will notify you by email at least 14 days before they take effect.

9.2 Your continued use of FormationFX after the effective date of any updated Terms constitutes acceptance of the new Terms.

10. Termination

10.1 You may stop using FormationFX and request account deletion at any time. See the Privacy Policy for data deletion details.

10.2 FormationFX may suspend or terminate your account if you breach these Terms (including breach of the §1.5 Eligibility warranty), if we receive a valid legal order, or if we discontinue the service.

11. Governing Law and Jurisdiction

These Terms are governed by the law of England and Wales. Any disputes shall be subject to the exclusive jurisdiction of the courts of England and Wales.

12. Contact

For questions about these Terms, contact: [email protected]

Simulated Teams

FormationFX leagues may include simulated teams that FormationFX manages alongside teams run by real users. Simulated teams trade against the same real-time market data as real users, using one of a small set of fixed strategies; their results reflect actual market movements and are not pre-determined.

Every simulated team is identified on its profile page with the words "Managed by FormationFX" and "Simulated team". League tables, weekly summaries, and match reports do not visually distinguish simulated teams from real users, by design.

Simulated teams are leaderboard opponents only. They do not affect the calculation of your own portfolio's returns and, where you have connected a real brokerage account, they do not affect any real trade executed in that account.

FormationFX intends to reduce the proportion of simulated teams over time as the real-user base grows. This is an operational intention, not a contractual commitment to a particular rate or schedule.

14. Order Transmission Policy

14.1 Scope. This section applies when you use the Rebalance Portfolio feature to submit trade instructions through the FormationFX platform. It does not apply to paper-trading (simulated) activity, which is governed by the paper-trading terms embedded in the relevant in-app disclosure.

14.2 Role of FormationFX. FormationFX is a transmission-only firm for the purposes of executing real-money portfolio rebalancing. When you confirm a rebalancing trade set, FormationFX transmits your individual trade instructions to Alpaca Securities LLC ("Alpaca"), which acts as the executing broker. FormationFX does not itself execute trades, hold client money, or act as a counterparty to any transaction.

14.3 Executing Broker. Your orders are routed exclusively to Alpaca Securities LLC, 237 Park Avenue, Floor 4, New York, NY 10017, USA, a member of FINRA and SIPC, registered with the SEC as a broker-dealer, and the Alpaca Connect brokerage partner through which you have opened your linked brokerage account. Alpaca is the sole executing venue for trades placed through FormationFX. Alpaca's own best-execution policy governs how your orders are executed and at what price. FormationFX does not determine the final execution price, fill quantity, or the sequence of order routing within Alpaca's systems. A summary of Alpaca's best-execution arrangements is available at alpaca.markets.

14.4 User Authorisation Required. FormationFX will never submit a trade instruction to Alpaca without your explicit per-event confirmation of the proposed trade set. There is no automated, recurring, or autonomous execution. "Formation targets" displayed on screen are derived from your chosen tactical formation and are a game construct, not investment advice. They suggest how your portfolio might be distributed across asset classes consistent with your formation choice; they do not constitute a regulated recommendation.

14.5 Paper vs Live Mode.

(a) Paper trading (default). When the live-rebalancing feature is inactive (the platform default), all rebalancing activity is simulated on paper. No orders are transmitted to Alpaca and no real money is moved. Paper-trading activity is labelled clearly on screen.

(b) Live trading (Legal-gated). Real-money order transmission to Alpaca is only enabled once FormationFX has received explicit Legal and board sign-off on the full live-trading build, including confirmation that all regulatory documentation required by this §14 is live. Until that sign-off, this section governs the intended live-trading terms for disclosure purposes only.

(c) Default-path users: no Alpaca link. Until you explicitly activate the Alpaca Connect feature, FormationFX does not link your account to any Alpaca brokerage account, does not store any Alpaca credentials, and no orders are transmitted.

14.6 Order Types. The Rebalance Portfolio feature submits market orders to Alpaca. Market orders execute at the prevailing market price at the time of execution. This price may differ — sometimes materially — from the indicative price shown on the preview screen. Limit orders are not available in the current version. Fractional shares will be used where Alpaca supports fractional trading for the relevant instrument and where the calculated trade size produces a sub-whole-share amount.

14.7 Partial Fills. Alpaca may partially fill an order where insufficient market liquidity exists for the full order quantity, or where the order is otherwise cancelled before full execution. In the event of a partial fill:

(a) FormationFX will notify you of the executed portion, the unfilled portion, and the reason (where available);

(b) FormationFX cannot guarantee that a rebalancing event will be fully executed; and

(c) where a partial fill leaves your portfolio allocation materially different from your formation target, you may initiate a further rebalancing event at your discretion.

14.8 Market-Hours Behaviour. Market orders can only execute when the relevant exchange is open for trading.

(a) If you confirm a rebalancing event while the relevant exchange is closed, FormationFX will not automatically queue the orders for execution at market open. You will be informed that the market is currently closed and will need to confirm the trade set again when the market reopens.

(b) If the market closes or a trading halt occurs between your confirmation and Alpaca's execution, any unexecuted orders will be cancelled and you will be notified.

14.9 Cancellation.

(a) Pre-confirmation: You may cancel at any point before tapping "Confirm Trades" — no orders will be submitted to Alpaca.

(b) Post-confirmation, pre-fill: FormationFX will attempt to cancel your pending order via Alpaca's cancellation API. Cancellation is not guaranteed if Alpaca has already begun execution. FormationFX will notify you of the cancellation outcome as soon as Alpaca confirms it.

(c) Post-fill: Once an order has been filled by Alpaca, FormationFX cannot reverse the executed trade. If you wish to return to a previous allocation, you must place offsetting trades. FormationFX does not provide investment advice on whether offsetting trades are appropriate.

14.10 Alpaca's Terms. By using the Rebalance Portfolio feature in live-trading mode, you are also bound by Alpaca's brokerage customer agreement and terms of service, which you accept when you connect your Alpaca account. In the event of any conflict between these Terms and Alpaca's terms in respect of matters within Alpaca's control (including trade execution, settlement, and margin), Alpaca's terms prevail.

14.11 Appropriateness Disclosure. On first use of the Rebalance Portfolio feature in live-trading mode, you will be asked to confirm that you understand:

(a) this feature places real trades using real money in your Alpaca brokerage account;

(b) formation targets are a game construct and do not constitute investment advice;

(c) your capital is at risk and you may receive back less than you invest; and

(d) FormationFX does not provide investment advice or manage your investments on a discretionary basis.

This acknowledgment is a Consumer Duty transparency step, not a formal appropriateness test under COBS 10A (the instruments available through FormationFX are non-complex instruments for the purposes of UK MiFID II).

14.12 Risk Disclosure. Capital at risk. The value of investments can fall as well as rise, and you may get back less than you invest. Past performance is not a reliable indicator of future results. FormationFX does not provide investment advice. Your formation is a game mechanic, not financial advice. Before investing in real securities you should consider whether investing is right for you and, if in doubt, seek independent financial advice.

14.13 Record-keeping. FormationFX maintains records of all trade instructions and execution reports in accordance with FCA record-keeping rules (SYSC 9.1.1R / COBS 11.5.1R) for a period of 7 years from the date of the relevant transaction. These records may be disclosed to the FCA, ICO, Financial Ombudsman Service, HMRC, or other competent authorities on lawful request.

14.14 Annual Review. FormationFX will review and, where necessary, update this Order Transmission Policy at least annually and whenever Alpaca's routing or execution arrangements materially change. Material changes to this policy will be communicated to you in accordance with the notice provisions in these Terms. Continued use of the Rebalance Portfolio feature after notification of a material change constitutes acceptance of the revised policy.

14.15 Alpaca Connect Authorisation. The Rebalance Portfolio live-trading feature operates through an OAuth authorisation that you grant to FormationFX.

(a) Grant of access. By connecting your Alpaca account via the in-app Connect flow, you grant FormationFX OAuth access to your Alpaca brokerage account for the purpose of submitting order instructions at your direction.

(b) Scopes. The OAuth scopes requested by FormationFX are limited to order placement only. FormationFX does not request or receive scopes that would allow it to withdraw funds, transfer assets, or modify account settings within Alpaca.

(c) Revocation. You may revoke FormationFX's OAuth access at any time by (i) disconnecting via Account Settings → Connected Services within FormationFX, or (ii) revoking the FormationFX application directly within your Alpaca account settings at alpaca.markets. Either action immediately terminates FormationFX's ability to submit further orders to your Alpaca account.

(d) Credential deletion. On revocation or account erasure, the Alpaca OAuth credential (access token, refresh token, and account identifier) stored by FormationFX is deleted from the FormationFX primary database within 30 days. See the Privacy Policy §2.8 for the full data-handling details.

FormationFX — Matthew Hall (sole trader) — England and Wales Beta 0.3 Final — Amendment 3 (OSA prohibited-content + mandatory reporting) — effective 20 June 2026