Points Program

Participation in the Novig Points Program is governed by these Terms and Conditions, together with the Ludlow Rulebook (the "Rulebook") and the Ludlow Member Agreement (the "Member Agreement"), including the MANDATORY ARBITRATION and CLASS ACTION WAIVER provisions in Sections 22–25 of the Member Agreement, by which you remain bound. Please read them carefully. Capitalized terms used but not defined here have the meanings given in the Rulebook and the Member Agreement.

How It Works

Opt in, then earn Points on your executed trading activity. Points move you through five monthly tiers: Starter, Bronze, Silver, Gold, and Obsidian. Higher tiers unlock rewards such as Trade Credits, Deposit Matches, themed share slips, and a share of a monthly cash pool. Points are used only to determine your tier for the month; they have no cash value and cannot be withdrawn.

1. Description of Program

Welcome to the Novig Points Program (the "Program"), where Members who opt in and meet the eligibility requirements may accrue points ("Points"), reach monthly tiers, and unlock rewards based on their monthly activity. The Program is offered by Ludlow Exchange, LLC, d/b/a Novig ("Novig" or the "Exchange"), a Commodity Futures Trading Commission-designated contract market, located at 169 Madison Avenue #2199, New York, NY 10016. The terms "you" or "your" mean the Member who participates in the Program. Participation in the Program is voluntary and requires affirmative opt-in, and is expressly conditioned upon acceptance of and compliance with these Terms and Conditions (these "Terms"), the Rulebook, and the Member Agreement. A Point does not create any property or contractual right and has no cash value. ANY DISPUTE RELATING TO THIS PROGRAM WILL BE RESOLVED IN ACCORDANCE WITH SECTION 17 BELOW, AND PARTICIPANTS WAIVE THE ABILITY TO BRING CLAIMS IN A CLASS ACTION FORMAT.

2. Acceptance of Terms

By opting in to, accessing, or participating in the Program, including by earning Points, you acknowledge that you have read, understood, and agree to be bound by these Terms, the Rulebook, and the Member Agreement, as each may be amended from time to time. To the extent of any conflict, the order of precedence set forth in the Member Agreement applies (Rulebook, then Member Agreement, then these Terms). If you do not agree to these Terms, the Rulebook, and the Member Agreement, you may not participate in the Program.

3. Program Period

The effective period of the Program will be announced by notice on the Novig website ("Notice") and may be retroactive to the Program's self-certification filing date. The Program will expire one year from its implementation date, unless extended by Novig, and remains subject to Novig's right to modify, suspend, or terminate the Program under Section 10.

The Program operates on monthly cycles (each a "Monthly Period"). Each Monthly Period begins at a fixed time on the first calendar day of a month and ends at the corresponding time on the first calendar day of the following month, as specified by Notice (currently 6:00 AM Eastern Time ("ET") to 5:59 AM ET). Points earned during a Monthly Period determine your tier status for that same Monthly Period, with your tier status updating during the Monthly Period as the applicable Point thresholds specified by Notice are reached. New Participating Members begin at the Starter tier and may advance during their first Monthly Period as those thresholds are reached. Point totals used for tier qualification reset to zero at the start of each new Monthly Period and do not carry forward.

4. Eligibility & Registration

Participation is voluntary and requires affirmative opt-in. A Member becomes a participant (a "Participating Member") only upon opting in, through onboarding or through the Novig app or website. A Member who has not opted in earns no Points and accrues no tier status. A Participating Member may opt out at any time through the Novig app or website. The consequences of opting out are set forth in Section 9.

The Program is open to all Members who opt in and meet the eligibility requirements, except the following, who are not eligible to participate: (i) Affiliates of the Exchange (as defined in the Rulebook); (ii) Members who have executed a market maker agreement or entity onboarding agreement with the Exchange; and (iii) Introducing Brokers ("IBs"), Futures Commission Merchants ("FCMs"), and their customers when transacting via the IB or FCM. All Participating Members remain subject to the Rulebook.

To remain eligible, you must, at the relevant time: (a) maintain an active account that has not been suspended, restricted, or terminated; (b) not be subject to a self-exclusion; (c) be in compliance with the Rulebook in all material respects; and (d) have satisfied all applicable verification requirements imposed by the Exchange or its partner clearinghouse. If you cease to meet these requirements, you will immediately cease to be eligible to earn additional Points, and your Points, tier status, and unredeemed rewards are subject to forfeiture under Section 9.

Re-enrollment upon new Terms. Your opt-in applies only to the version of these Terms in effect at the time you enroll. If Novig publishes new or updated Terms for the Program, your existing enrollment will not carry over. To continue earning Points, and to remain eligible to receive rewards and cash prizes under the Program, you must affirmatively opt in again to the new Terms through the Novig app or website. Until you opt in to the new Terms, you will not earn Points and will not be eligible to receive rewards or cash prizes under the Program.

5. Limitations on Participation

In addition to the eligibility requirements in Section 4, Novig reserves the right to refuse or restrict your participation in the Program where necessary to protect the integrity of the Program or the market, to prevent abuse, or as otherwise consistent with the purpose of the Program or the Rulebook, including based on your trading patterns or trading history. This Program is void where prohibited by law.

6. How to Earn Points

You earn Points solely on executed Trades and on completion of objectives tied to executed trading activity. Trades executed through programmatic or automated means do not accrue Points. Points accrue through the following mechanisms:

The number of Points awarded under each mechanism, the eligible markets and price ranges, and the applicable challenge objectives are specified by Notice for each Monthly Period, as early as practicable and in any event before the start of the Monthly Period to which they apply.

7. Tiers and Rewards

Accumulated Points within a Monthly Period advance you through five tiers: Starter, Bronze, Silver, Gold, and Obsidian. Crossing a tier unlocks rewards, which may take the form of Reward Credits and non-cash share slips that are not redeemable for cash. "Reward Credits" means credits and similar trading benefits awarded under the Program, including but not limited to Trade Credits and Deposit Matches. Cash prizes are not unlocked or earned at the time you cross a tier threshold; they are determined and paid only after the end of the Monthly Period, as distributions from the Monthly Pool described below, based on the highest tier you attain during that Monthly Period. The forms of reward associated with each tier need not be uniform, and not every tier unlocks every form of reward. The Point threshold required to attain each tier, and the rewards associated with each tier, are specified by Notice.

Monthly Pool. At the end of each Monthly Period, Novig will allocate a promotional reward pool (the "Monthly Pool"), funded by the Exchange, among eligible Participating Members as cash prizes based on the highest tier attained during that Monthly Period, with higher tiers receiving larger prizes. The amount of the Monthly Pool is specified by Notice. The Monthly Pool is allocated among eligible Participating Members according to a fixed, predetermined methodology that Novig applies on a consistent, non-discriminatory basis to all similarly situated Participating Members. Monthly Pool distributions are paid as cash credited to your Exchange account.

8. Restrictions on Redemption

Points are non-transferable, have no cash value, and may not be redeemed for cash or withdrawn from the Exchange. Reward Credits may be used solely for trading on, or deposits to, the Exchange as applicable to the particular type of Reward Credit, and may not be transferred, redeemed for cash, or withdrawn.

Each type of Reward Credit is subject to the claiming period, usage period, eligible prices, usage limits, and other conditions specified by Notice, which conditions form part of these Terms; any Reward Credit not claimed or used in accordance with those conditions is forfeited. Reward Credits may not be deployed through programmatic or automated trading. Monthly Pool distributions, once credited as cash to your Exchange account, are withdrawable in accordance with the Rulebook and the Member Agreement.

9. Forfeiture, Adjustment, and Clawback

9.1 Forfeiture. Your Points balance, tier status, and any unredeemed rewards are immediately forfeited, without compensation, upon (a) closure, suspension, or termination of your account; (b) your becoming subject to a self-exclusion; (c) your opt-out from the Program; or (d) termination of the Program.

9.2 Restoration. Novig has no obligation to restore forfeited Points, tier status, or rewards, but may, in its sole discretion, restore all or a portion in exceptional circumstances. Any restoration request must be submitted to [email protected] within thirty (30) days of the event giving rise to the forfeiture. Novig's decision is final and may be granted or denied for any reason without establishing any precedent or future obligation.

9.3 Adjustment and Clawback. Novig may adjust, reduce, cancel, or claw back any Points, tier status, or rewards credited to your account where: (i) they were credited in error, including as a result of a technical malfunction, system error, inaccurate data feed, or administrative mistake; (ii) the Trade or transaction giving rise to the Points has been voided or cancelled; (iii) the underlying payment or deposit associated with the qualifying activity is charged back or otherwise not honored; (iv) Novig determines, in its sole discretion, that they were obtained through fraud, misrepresentation, collusion, bonus abuse, multi-accounting, or other activity inconsistent with the Rulebook or this Program; or (v) Novig is required to void or reverse the underlying transaction by Applicable Law or by directive of a competent regulatory authority.

9.4 No Vested Rights. Points and tier status do not constitute your property, have no cash value, and are not transferable. You have no vested right in any Points balance or tier status.

10. Program Changes & Termination

Novig may modify, suspend, or terminate the Program, or any part of it, at any time, subject to applicable CFTC filing requirements and to the parameters of the Program as filed. The fixed values set forth in these Terms apply for the term of the Program. Novig may adjust, cancel, or substitute any reward that has not yet been claimed. Rewards already claimed but not yet redeemed are subject only to the adjustment and clawback grounds set forth in Section 9. No change to the rate at which Points are earned applies retroactively to qualifying activity completed before the effective date of the change. Where reasonably practicable, Novig will provide advance notice of material changes by Notice, in-app notification, or email; Novig may make immediate changes required by Applicable Law or regulatory directive. Novig conducts ongoing surveillance of Program activity pursuant to Chapter 9 of the Rulebook, and the Chief Regulatory Officer retains sole discretion to revoke a Participating Member's eligibility, disqualify Trades or activity inconsistent with the purpose of the Program or the Rulebook, and modify, suspend, or terminate the Program at any time. Where the Chief Regulatory Officer concludes that a Participating Member's participation is abusive or otherwise inconsistent with the purpose of the Program, that Member's Points, tier status, and any unredeemed rewards are automatically forfeited to the Exchange.

11. Self-Exclusion

If you are subject to a self-exclusion, you are ineligible to participate in the Program for the duration of that exclusion, and your Points, tier status, and unredeemed rewards are subject to forfeiture under Section 9. Novig may immediately suspend your ability to earn Points upon becoming aware of a self-exclusion, without prior notice.

12. Privacy & Data Use

Participation in the Program is subject to the Novig Privacy Policy (the "Privacy Policy"), which is incorporated into the Member Agreement. By participating, you acknowledge that Novig may collect, use, and process data generated through Program participation, including Points-earning activity and tier status, in accordance with the Privacy Policy.

13. Intellectual Property

All names, marks, logos, Program mechanics, and content associated with the Program are the proprietary intellectual property of Novig and are protected by applicable intellectual property laws. Participation in the Program does not grant you any license or right to use Novig’s intellectual property. You may not reproduce, modify, distribute, or otherwise exploit any Program-related intellectual property without Novig's prior written consent.

14. Tax Disclosure

You are solely responsible for all tax obligations arising from participation in the Program, consistent with Section 5.9 of the Member Agreement.

15. Limitation on Liability

Novig's liability for any Program-related claim is governed by Section 19 of the Member Agreement, which limits liability and disclaims responsibility for, among other things, the loss of any trading incentive or bonus. Points have no cash value, and Novig has no liability for the loss of Points, loss of tier status, or the modification or termination of the Program under Section 10.

16. Complaint & Cancellation

Should you wish to cancel your participation in the Program at any time, please contact [email protected]. Upon cancellation, your Points balance is forfeited in accordance with Section 9. To submit a complaint regarding the Program, contact [email protected] with a description of your complaint and the remedy you are seeking; such complaints are subject to the informal dispute resolution process described in Section 17.

17. Dispute Resolution

Any dispute relating to this Program is a "Dispute" governed by the informal dispute resolution, mandatory arbitration, and class action waiver provisions of the Member Agreement (Sections 22–25) and Chapters 10–11 of the Rulebook, including the opt-out rights and carve-outs set forth therein.

18. General Terms

18.1 Severability. If any provision of these Terms is found invalid or unenforceable, that provision is severed and the remainder continues in full force and effect.

18.2 Waiver. Novig's failure to enforce any provision at any time is not a waiver of its right to do so later.

18.3 Entire Agreement. These Terms, together with the Rulebook, the Member Agreement, and the Privacy Policy, constitute the entire agreement between the parties with respect to the Program and supersede all prior understandings relating to the Program.

18.4 Survival. Sections 9, 13, 14, 15, 16, 17, and this Section 18 survive termination of the Program or these Terms.

18.5 Assignment. Novig may assign these Terms without notice or your consent. You may not assign your Program participation, account, or Points balance; any purported assignment by you is void.

18.6 Amendments. Novig may amend these Terms from time to time, with amendments reflected on the Novig platform and, where material, subject to applicable CFTC filing requirements. Except where Novig publishes new or updated Terms that require re-enrollment under Section 4, your continued participation after an amendment is posted constitutes acceptance.

18.7 Governing Law. These Terms are governed by the laws of the State of New York, consistent with Section 34 of the Member Agreement.

18.8 Release. By participating in the Program, you agree to release, defend, indemnify, and hold harmless the Exchange and its directors, officers, and employees, consistent with Rule 12.3 of the Rulebook.