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Contract reading

What Upway legally published, but does not want you to read

Every clause below is published by Upway itself, on its own website, today. The finding is not that the text exists. It is the distance between what a client is shown and what a client agreed to. Read from its own documents on .

Contracting entity: Up Way China Bullion Limited

hidden feesole discretionlanguage arbitragemarketing mismatchwithdrawalsdormancykyc freezeprofit voidingaccount closurebalance absorption

Upway can take 6% of your deposit as a fee when you withdraw, if you did not trade enough after depositing. Its own pricing page advertises zero fees. An idle account loses $5 every 60 days until the balance is gone. The English contract and the Chinese contract name two different companies as the one you are signing with.

Contract risk

Money at risk
8.0/10

Where this contract sitsHow far this contract goes, overall. Under 2 is nothing beyond the ordinary; 6 to 9 means several clauses put money you have already earned at risk; 9 and above reads as designed to make payout refusable.

0510
CriticalClauses that can cost you money you have already earned or deposited, or that remove your ability to challenge it.
7
FlaggedEvery clause worth knowing about, at all three severities. Ordinary terms that every broker has are not counted.
18
DocumentsHow many of the broker's own legal files this reading is based on. Each one was downloaded and hashed on the date shown.
5
ContradictionsPlaces where a promise the broker makes in public is not kept by the clause that governs it.
5

How the 18 break downThe same flagged clauses, split by how much each one can cost you. Severity is our reading of the clause, not the broker's label.

Critical7
Warning8
Notice3

section 38 of 93is where the deepest clause sits, 41% of the way into the document it is in

The numbers in this contractFigures taken from this broker's own clauses, so the labels differ from broker to broker. The four in the panel above are the same on every report.

3 of these 4 figures come from a clause we rate critical, which means it can take your money or your profit rather than only delay it.

What the documents say

18 clauses worth knowing about, worst first, each quoted from Upway's own files

01

Deposit money, trade less than half that amount, and Upway takes 6% of what you deposited when you withdraw. The fee sits in clause 11 of the user agreement, under Withdrawal. Trade enough and you get three free withdrawals a day instead.

Why this matters

Put in $1,000, change your mind, and $60 is gone before you have placed a single trade. The percentage is charged on your deposit, not on the smaller sum you take out.

Exhibit 1CriticalRarely seen6%

If the Client’s trading volume after deposit is less than 50% of the deposit amount, a withdrawal fee equal to 6% of the deposited amount will be deducted.
Clause 11 (Withdrawal, item 4) in UPWAY User Agreement
Downloaded from the broker's site on Open the reference

What it costsA $1,000 deposit withdrawn without meeting the volume test returns $940. The $60 is 6% of the deposit, not of the withdrawal.

Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA and CySEC must tell a retail client the costs and charges of a service before they trade. Upway publishes this 6% charge only in the user agreement, and not on the page where it sets out what trading costs.

Upway is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

Our readingA withdrawal fee is normally a flat charge or a percentage of the amount leaving. Upway calculates it on the sum you paid in, and triggers it by how little you traded, so the charge grows with your deposit while the withdrawal shrinks it.

  • Worse together with Exhibit 11A bonus you cannot read the rules for encourages a deposit, and this clause charges you 6% of that deposit to take it back out untraded.
02

Leave the trading platform unopened for 60 days with money still in the account, and Upway starts taking $5 every 60 days. Clause 15.5 says it keeps taking it until the balance is depleted. Logging into the website or the member centre does not count.

In plain words

Dormancy means an account left unused.

Why this matters

A forgotten account empties itself into Upway with nobody deciding anything. You have to open the trading app to stop the clock, and checking your balance on the website will not do it.

Exhibit 2CriticalHarder than usual$5

The system will automatically deduct 5 USD every 60 days as the account management fee until the account balance is depleted.
Clause 15.5 in UPWAY User Agreement
Downloaded from the broker's site on Open the reference
Our own capture of jrjr.com, taken on Sep 1, 2026$5 every 60 days until an idle balance is gone (clause 15.5)Visit this page on the broker's siteDownload the full size image file

What it costsAn account left with $40 and no platform login loses $5 every 60 days. After 480 days the balance is zero.

Our readingDormancy fees are ordinary. Two things here are not: the fee runs until the balance reaches zero rather than stopping at a floor, and the only action that resets the clock is opening the trading platform itself.

What happens, and when

The stages this clause runs through, taken from the broker's own document
TriggerWhat the broker may then doClause
Day 60Upway takes $5 from an account with a positive balance that has not opened the trading platform.15.5
Day 90Upway can close the account outright after 90 days with no successful login to the trading system.15.5
Balance depletedThe charge repeats every 60 days until nothing is left in the account.15.5
03

Upway can take back the profit you made and every bonus it gave you, on suspicion alone. The clause asks for no proof and offers no appeal. Upway decides what counts as manipulation and settles any argument about it itself.

Why this matters

Your winning trades can be reversed out of your balance while you are still asking why. Upway makes the accusation and then rules on it.

Exhibit 3CriticalHarder than usual

If Upway Global suspects any account of engaging in manipulation, it reserves the right to investigate and review the account and may deduct any profits earned from such activities and all promotional incentives returned by the platform from the suspected account.
Clause Client Notice 6 in UPWAY User Agreement
Downloaded from the broker's site on Open the reference
Our own capture of jrjr.com, taken on Sep 1, 2026Profit removed from an account Upway merely suspects (clause Client Notice 6)Visit this page on the broker's siteDownload the full size image file
  • Worse together with Exhibit 7One clause lets Upway take the profit on suspicion, the other makes Upway the only judge of whether the suspicion was fair.
04

Read the agreement in English and you contract with Up Way China Bullion Limited. Read the same opening clause in Chinese and you contract with 金荣中国金融业有限公司. Neither version mentions the other company.

Why this matters

You cannot tell which company holds your money until something goes wrong. Clause 27 then sends you to Hong Kong to work out which one you are suing.

Exhibit 4CriticalRarely seen2

This User Agreement (hereinafter referred to as the “Agreement”) is legally binding and is entered into by Up Way China Bullion Limited (hereinafter referred to as “Upway Global” or the “Company”), a company incorporated under the laws of the Hong Kong Special Administrative Region
Clause (B) Client Notice in UPWAY User Agreement
Downloaded from the broker's site on Open the reference
Our own capture of jrjr.com, taken on Sep 1, 2026Two different companies sign the same agreement (clause (B) Client Notice)Visit this page on the broker's siteDownload the full size image file

Our readingBrokers commonly run several entities and say which client gets which. Here the same numbered clause of the same agreement names a different company in each language, with no clause anywhere linking the two names.

  • Worse together with Exhibit 16You must sue in Hong Kong and give up every objection to that venue, without the contract settling which of the two companies you would be suing.
05

Upway's own trading rules page promises 零手续费, zero fees, beside a commission of $0. The user agreement then charges up to 6% to take your money out, $3 on withdrawals under $50, and $5 every 60 days on an idle account.

Why this matters

The page that tells you what trading costs does not mention any of these charges. They live in an agreement reached by a small link at the foot of the site.

Exhibit 5CriticalHarder than usual6%

If the Client’s trading volume after deposit is less than 50% of the deposit amount, a withdrawal fee equal to 6% of the deposited amount will be deducted.
Clause 11 (Withdrawal, item 4) in UPWAY User Agreement
Downloaded from the broker's site on Open the reference
Our own capture of jrjr.com, taken on Sep 1, 2026The claim, on English trading rules page, under the heading Lower CostsVisit this page on the broker's siteDownload the full size image file
Our own capture of jrjr.com, taken on Sep 1, 2026What the contract says, clause 11 (Withdrawal, item 4)Visit this page on the broker's siteDownload the full size image file
  • Same clause as Exhibit 1The zero fees promise and the 6% charge rest on the same withdrawal clause read against the same pricing page.
06

Upway can freeze your withdrawals while it looks into suspected arbitrage, and the clause puts no outer limit on how long that lasts. Upway alone decides when the issue is fully resolved.

Why this matters

Your money can sit unavailable for as long as Upway needs. The agreement gives you no complaints procedure to challenge the freeze and no deadline it has to meet.

Exhibit 6CriticalHarder than usual

Upway Global reserves the right to freeze client withdrawals until the issues are fully resolved.
Clause Client Notice 5 in UPWAY User Agreement
Downloaded from the broker's site on Open the reference
Our own capture of jrjr.com, taken on Sep 1, 2026Withdrawals frozen until Upway decides the matter is closed (clause Client Notice 5)Visit this page on the broker's siteDownload the full size image file
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA or CySEC must let a retail client have their money back promptly and must keep it separate from the firm's own money. This agreement lets Upway hold a withdrawal until it decides a suspicion is fully resolved, with no time limit written down.

Upway is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

  • Worse together with Exhibit 7The freeze has no deadline and the only person who can rule that it went on too long is Upway.

Upway settles the disputes that are about Upway

Upway's agreement sends every price and execution dispute to its own final interpretation, and you agree in advance to abide by the result. No complaints procedure appears anywhere in the document. Clause 19 then limits Upway's liability to losses it caused by intentional fault or fraud.

No appeal2 clauses flagged

Every argument about a price or an execution goes to Upway's own final interpretation, and you agree in advance to accept its ruling. The agreement sets out no complaints procedure at all.

Why this matters

You have no independent body to appeal to when a trade goes against you. The company you are complaining about writes the last word on it.

Exhibit 7CriticalHarder than usual

All related disputes shall be subject to the final interpretation by Upway Global, and the Client agrees to abide by Upway Global’s determination.
Clause Client Notice 4 in UPWAY User Agreement
Downloaded from the broker's site on Open the reference
Our own capture of jrjr.com, taken on Sep 1, 2026Upway is the final judge of every dispute (clause Client Notice 4)Visit this page on the broker's siteDownload the full size image file
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA must follow set complaint handling rules and tell a retail client they can take an unresolved complaint to the Financial Ombudsman Service. CySEC firms must run a complaints procedure and point clients to the Financial Ombudsman of Cyprus. This agreement names no complaints procedure and makes Upway the final interpreter of any dispute.

Upway is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

Upway is liable to you only for direct losses it caused by intentional fault or fraud, under clause 19. A mistake, a system failure or an outage leaves you with no claim. Clause 20 then has you cover its legal costs.

Why this matters

Proving a company meant to harm you is far harder than proving it slipped. Most things that go wrong on a trading platform are slips.

Exhibit 8WarningHarder than usual

Upway Global is only responsible for direct losses caused by its intentional fault or fraudulent acts, and shall not be liable for losses caused by the fault of other parties.
Clause 19 in UPWAY User Agreement
Downloaded from the broker's site on Open the reference

Upway's pricing page says zero fees while its contract charges 6%

Upway's trading rules page advertises 零手续费, zero fees, beside a commission of $0. Its user agreement charges 6% of your deposit to withdraw when trading volume is low. The same site advertises transfers in seconds with no review, which the agreement locks across every weekend.

Language arbitrage1 clause flagged

Upway advertises transfers between your wallet and your trading account in seconds, with no review. The agreement locks those transfers from 30 minutes before the weekend close until 30 minutes after the market reopens.

Why this matters

You cannot move money out of a flagged trading account over the weekend. The lock lands exactly when you might want to cut your exposure before the market gaps.

Exhibit 15WarningHarder than usual

For any account that triggers the risk-control mechanism, a fund transfer lock period will apply from 30 minutes before the weekend market closes until 30 minutes after the market reopens.
Clause 11 (Wallet, item 3) in UPWAY User Agreement
Downloaded from the broker's site on Open the reference
Our own capture of jrjr.com, taken on Sep 1, 2026The claim, on Chinese homepage, under the heading 极速资金划转 (ultra fast fund transfers)Visit this page on the broker's siteDownload the full size image file
Our own capture of jrjr.com, taken on Sep 1, 2026What the contract says, clause 11 (Wallet, item 3)Visit this page on the broker's siteDownload the full size image file

Every route out of an Upway account has a price on it

Upway charges 6% of your deposit to withdraw it when your trading volume stays under half that deposit. Withdrawals under $50 cost $3. Closing a position with a trade code costs $0.5 a lot, and a Hong Kong dollar payout converts at a fixed 7.8 that Upway can change without notice. None of these appear on the page where Upway publishes its trading costs.

Cost disclosure2 clauses flagged

Take your money out in Hong Kong dollars and Upway converts it at a fixed rate of 7.8. Clause 6 lets Upway change that rate whenever the market moves, without telling you first.

Why this matters

The rate you are paid at is set by Upway, not by the market. A change costs you the difference and arrives with no warning.

Exhibit 12WarningHarder than usual

客户如欲以港元取款,本公司将按照固定汇率7.8将美元兑换成港元。本公司有权根据市场情况,无需预先通知客户,变更上述汇率。
Clause 6.2 in 金荣中国用户使用协议
Read from the broker's site on Open the reference

Upway markets trade codes as the way to check your orders at the Hong Kong exchange. Opening a position is free. Closing one costs $0.5 a lot, and clause 11 lets Upway stop providing codes at its absolute discretion.

Why this matters

The feature that proves your trade reached the exchange can be switched off by the company it would be checking. Verifying your closed trades costs you $0.5 for every lot.

Exhibit 13WarningHarder than usual$0.5

金荣中国免费提供建仓交易编码,平仓交易编码收费按1手0.5美元比例收取。
Clause 11(交易编码)2 in 金荣中国用户使用协议
Read from the broker's site on Open the reference

Upway advertises $29,800 in bonuses and publishes no rules for them

Upway offers new users up to $29,800 in bonus credit and publishes no bonus terms on the promotions page. The user agreement mentions bonuses only to describe removing them. A failed identity check takes back every bonus and spread rebate, and so does a withdrawal made without trading.

Bonus terms1 clause flagged

Upway advertises new user bonuses worth up to $29,800 and publishes no terms for them anywhere on the promotions page. The user agreement mentions bonuses only to describe taking them back.

Why this matters

You cannot find out what a bonus requires of you before you accept it. You can find out how you lose it: fail a check, or withdraw without trading.

Exhibit 11WarningHarder than usual$29800

If the Client applies for withdrawal without trading after deposit, fees may apply, and any bonuses received may be deducted.
Clause 11 (Withdrawal, item 5) in UPWAY User Agreement
Downloaded from the broker's site on Open the reference
Our own capture of jrjr.com, taken on Sep 1, 2026The claim, on Chinese promotions page, current campaign banner with a live countdownVisit this page on the broker's siteDownload the full size image file
Our own capture of jrjr.com, taken on Sep 1, 2026What the contract says, clause 11 (Withdrawal, item 5)Visit this page on the broker's siteDownload the full size image file

Upway can change the terms without telling you

Clause 16 lets Upway revise, cancel or replace any term and post the change with no prior notice and no announcement. You are told to review the terms regularly yourself. The dormancy rules in clause 15.5 already differ between the English and Chinese versions of the same agreement.

Unilateral change2 clauses flagged

Upway can revise, cancel or replace any term of the agreement whenever it chooses. Clause 16 says it posts the change on the site and the app without notifying you first. You are told to check regularly.

Why this matters

The contract you agreed to can be different tomorrow and nothing will tell you. Reading the page yourself is the only way to find out what changed.

Exhibit 9WarningHarder than usual

Upway Global will update such amendments or changes directly on its website (www.jrjr.com/en) and Upway APP without prior notice or publishing of the latest amendment announcement.
Clause 16 in UPWAY User Agreement
Downloaded from the broker's site on Open the reference

The English agreement closes your account after 90 days without a login to the trading system. The Chinese version of clause 15.5 acts only once the balance is zero. It then gives 60 days, plus 30 more, before deletion.

Why this matters

Which rule applies to your money depends on which language you read. The English wording puts no balance condition on closing the account at all.

Exhibit 10WarningHarder than usual90 days

No successful login to the trading system for more than 90 consecutive days.
Clause 15.5 in UPWAY User Agreement
Downloaded from the broker's site on Open the reference

Upway's contract says you trade with a market maker

Upway's agreement states that clients trade directly with market makers in the OTC market. Its homepage advertises an STP model with orders going straight to market and zero delay. Upway also sets the quote, and its own interpretation of any dispute about that quote is final.

Who takes the other side1 clause flagged

Upway's agreement describes clients as trading directly with market makers in the OTC market. Its homepage advertises an STP model where orders go straight to market. A market maker takes the other side of your trade, so your loss can be its gain.

Why this matters

Upway sets the quote, holds the other side of your position, and rules on any dispute about that quote. No outside reference price appears anywhere in the agreement.

Exhibit 14WarningHarder than usual

Arbitrage activities (such as profiting from price differences due to network delays) do not exist in OTC markets where clients trade directly with market makers.
Clause Client Notice 5 in UPWAY User Agreement
Downloaded from the broker's site on Open the reference
Our own capture of jrjr.com, taken on Sep 1, 2026The claim, on English homepage, under the heading Lightning-fast ExecutionVisit this page on the broker's siteDownload the full size image file
Our own capture of jrjr.com, taken on Sep 1, 2026What the contract says, clause Client Notice 5Visit this page on the broker's siteDownload the full size image file
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA and CySEC must disclose conflicts of interest to retail clients and take all sufficient steps to get the best result when executing an order. Upway's agreement describes clients trading directly with market makers, while its homepage advertises straight through processing to the market.

Upway is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

The company you contract with depends on the language you read

Upway's English agreement names Up Way China Bullion Limited as your counterparty. The Chinese version of the same opening clause names 金荣中国金融业有限公司. Clause 27 then sends every dispute to Hong Kong and has you waive all objections to that venue, without the contract ever settling which company you would be suing.

In plain words

On a principal basis, as your counterparty, means the broker takes the other side of your trade itself. Your loss is then the firm’s gain, so it has an interest in how your trade ends.

Counterparty1 clause flagged

Any claim against Upway has to be brought in Hong Kong. Clause 27 also has you give up every objection to that venue, and the right to move the case elsewhere.

Why this matters

Suing from outside Hong Kong means foreign lawyers and foreign court costs. For a balance of a few hundred dollars, that is not worth doing.

Exhibit 16NoticeStandard wording

The Client agrees to waive and relinquish any and all objections to such jurisdiction and further agrees to waive any rights to transfer or change the venue of such actions or legal proceedings under this Agreement
Clause 27.1 in UPWAY User Agreement
Downloaded from the broker's site on Open the reference

Upway keeps your personal data for seven years after you leave

Upway holds the personal information of a closed account for seven years from the closure date. Closing requires 15 days of cooling off first, with the account shutting on day 16. The same privacy policy page also carries an older section that gives no retention period at all.

Data retention1 clause flagged

Closing your Upway account starts a 15 day cooling off period, and the closure takes effect on day 16. Your personal information then stays on file for seven years. The same policy page also carries an older section that gives no retention period at all.

Why this matters

Your identity documents and bank card images outlast your account by seven years. Withdrawing consent is only possible if you owe Upway nothing.

Exhibit 18NoticeStandard wording15 days

在法律法规未另行规定更长的保存期限的情况下,金荣中国将在销户生效日起的7年内,对已销户客户的个人信息进行安全、彻底的删除或匿名化处理。
Clause 五.3.3 in 金荣中国隐私政策
Read from the broker's site on Archived copyOpen the reference

Where it sits: section 38 of 93 in the 金荣中国隐私政策, 41% of the way through.

Upway names a bullion exchange membership and no financial regulator

Upway's agreement claims class AA membership number 084 of the Hong Kong Gold Exchange. It names no financial regulator, no segregated client account and no compensation scheme. Our scam report is the place to weigh what that membership is worth.

What is named1 clause flagged

Upway describes itself in clause 12 as a class AA member, number 084, of the Hong Kong Gold Exchange. The agreement names no financial regulator. It names no segregated client account and no compensation scheme either.

Why this matters

Nothing in this contract says your deposit is held apart from Upway's own money. If the company fails, no scheme named in the agreement pays you back.

Exhibit 17NoticeHarder than usual

Upway Global is a class “AA” licensed member (no. 084) of the Hong Kong Gold Exchange.
Clause 12 in UPWAY User Agreement
Downloaded from the broker's site on Open the reference
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA or CySEC must hold retail client money in segregated accounts and belong to a statutory compensation scheme that pays out if the firm fails. This agreement names neither a segregated account nor a compensation scheme.

Upway is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

Where the marketing and the contract disagree

A promise made in public, set against the clause that governs it

01

The pricing page promises zero 手续费 while the agreement charges 6% under that exact word.

Said in public, in Chinese

零手续费/低点差结构,透明化计价模式

Word for word in English: Zero fees / low spread structure, transparent pricing model

Chinese trading rules page, under the heading 降低成本 (lower costs)

In the contract · clause 11(取款)4

客户注资后交易量不足注资金额50%,将扣取注资金额的6%作为取款手续费。

02

The English pricing page advertises zero commission and transparent pricing above a 6% withdrawal charge it never mentions.

Said in public, in English

Zero commission / low spread structure, transparent pricing model

English trading rules page, under the heading Lower Costs

We took a picture of this page. It is shown once, with the finding it belongs to. See our capture of jrjr.com

In the contract · clause 11 (Withdrawal, item 4)

If the Client’s trading volume after deposit is less than 50% of the deposit amount, a withdrawal fee equal to 6% of the deposited amount will be deducted.

We took a picture of this page. It is shown once, with the finding it belongs to. See our capture of jrjr.com

03

Transfers advertised as instant and free of review are locked across every weekend for any flagged account.

Said in public, in Chinese

金荣钱包与交易账户秒级互通,免审核极速划转。

Word for word in English: The Jinrong wallet and trading accounts connect within seconds, with ultra fast transfers requiring no review.

Chinese homepage, under the heading 极速资金划转 (ultra fast fund transfers)

We took a picture of this page. It is shown once, with the finding it belongs to. See our capture of jrjr.com

In the contract · clause 11 (Wallet, item 3)

For any account that triggers the risk-control mechanism, a fund transfer lock period will apply from 30 minutes before the weekend market closes until 30 minutes after the market reopens.

We took a picture of this page. It is shown once, with the finding it belongs to. See our capture of jrjr.com

04

A bonus advertised at up to $29,800 has no published terms, and the contract describes only how Upway takes it back.

Said in public, in Chinese

暑期黄金热 一夏新机遇!0元开户炒黄金 最高送$29800赠金

Word for word in English: Summer gold heat, new opportunities this summer! Open an account for 0 yuan to trade gold, with bonuses up to $29,800.

Chinese promotions page, current campaign banner with a live countdown

We took a picture of this page. It is shown once, with the finding it belongs to. See our capture of jrjr.com

In the contract · clause 11 (Withdrawal, item 5)

If the Client applies for withdrawal without trading after deposit, fees may apply, and any bonuses received may be deducted.

We took a picture of this page. It is shown once, with the finding it belongs to. See our capture of jrjr.com

05

The homepage says orders go straight to market while the agreement describes clients trading directly with market makers.

Said in public, in English

STP model – Orders go directly to market with zero delay execution.

English homepage, under the heading Lightning-fast Execution

We took a picture of this page. It is shown once, with the finding it belongs to. See our capture of jrjr.com

In the contract · clause Client Notice 5

Arbitrage activities (such as profiting from price differences due to network delays) do not exist in OTC markets where clients trade directly with market makers.

We took a picture of this page. It is shown once, with the finding it belongs to. See our capture of jrjr.com

The documents this reading is based on

5 files, all published by Upway. Each shows when we read it and a fingerprint of its wording.

WIKILIX keeps the copy of each file it read, and does not republish it: what is published is the fingerprint of its wording. Download the file yourself and hash its text, lowercased with runs of whitespace collapsed, and a matching fingerprint means the wording quoted above is still the wording Upway publishes.

How this reading was done

Every clause above was read out of a document Upway publishes itself

This reading was published on .

Documents
2 of 5downloaded from the broker's site, and 2 read in full
Pages opened
22pages walked to find those documents, footer links included
Marketing pages
7public pages set against what the contract says
Languages
EN vs ZHthe language it advertises in, against the language it contracts in
Position measured
1clauses whose position was counted: which numbered section of the document holds them, out of how many

Who the contract is with

Up Way China Bullion Limited

The English user agreement names Up Way China Bullion Limited as the company you contract with. The Chinese version of the same agreement, in the same opening clause, names 金荣中国金融业有限公司, and the site copyright line carries that second name. Neither document mentions the other company, and neither says the two are the same. Both describe a company incorporated in Hong Kong. Clause 12 claims class AA membership number 084 of the Hong Kong Gold Exchange, a bullion exchange, and the agreement does not describe that as financial regulation. It names no financial regulator, no segregated client account and no compensation scheme.

Quotations are copied verbatim from the documents named above, with the clause number and the page each one came from. Where a clause is quoted in another language, the original is shown first and the English is a translation.

The plain-language parts, what a clause means for a client, how ordinary it is, and how it reads against a regulated standard, are WIKILIX's analysis and are labelled as such on every card. This is a reading of public documents, not legal advice and not an allegation of wrongdoing.

In fairness, and what we could not check

A reader who knows the edges of the work can trust the middle of it

Upway pays the bank charges on deposits and on any withdrawal of $50 or more, which many brokers push onto the client instead. It commits to approving a withdrawal within 2 hours and publishes the arrival times it expects. The trading rules page sets out contract size, margin, overnight interest and the 30% forced liquidation level in one table, which is more pricing detail than most competitors put in public. The risk warnings in the site footer are blunt about losing everything.

We read the Chinese user agreement in full on Upway's own page at jrjr.com/pageshow/html/list_83.html, and every Chinese quotation comes from there. We read large parts of the English user agreement at jrjr.com/en/pageshow/html/list_83.html, but not every clause of it. We did not read the English privacy policy or the App Information page at all. No earlier copies of any of these documents were available, so we cannot say which clauses changed or when. Upway publishes no bonus terms, no complaints procedure and no client money policy, so on those subjects there was nothing to read.

How to check any of this yourself

Every quote above links to the Upway file it came from. This is what to do with it.

Open the three stepsFind the words in the source, work out the fingerprint, and read what a difference does and does not prove.

Open the source and search for the words

Every quote has a link under it. Open the file, or the web page, and search it for the words we quote. The clause number next to the quote tells you where to look.

If the words are not there any more, the source may have changed after we read it. That is worth knowing too. We keep the date we read it, and a code worked out from its wording, so the quote stays checkable.

What a fingerprint is

A fingerprint is a code worked out from what a source says. Change one word and the code changes completely. We keep two codes for every file we read, and the panel on each source shows both.

The first is the code of the exact file we downloaded. The second is the code of its wording alone, with capital letters lowered and runs of spaces collapsed. When the same words are saved as a new file, the first code changes and the second one stays the same.

Only the first code can be worked out on your own computer. Save the file, then run one of these, putting the name of the file you saved where the example is. The panel on each source prints the command with that source's real file name already in it.

macOS or Linux:
  shasum -a 256 the-file-you-saved.pdf

Windows:
  certutil -hashfile the-file-you-saved.pdf SHA256

The two codes are different from each other, and they are not meant to match. Comparing one against the other proves nothing.

What a difference means, and what it does not

A different file code on its own proves nothing. A PDF saved again with a new date inside it is a new file saying exactly the same thing.

A different wording code means the words themselves changed. That is the one that matters, and it is why we keep it.

Even then, a change is not proof of bad faith. Companies update their documents. What this report says is what the document said on the day we read it, and every quote carries that date.

A source that is a web page and not a file has no file to save, so only the code of its wording is shown.

How this report is made

Every clause quoted above comes from a document Upway publishes on its own website, downloaded and hashed on the date shown, with the clause number and page recorded so any reader can check it. We do not allege anything the documents do not say, and we do not judge Upway on anything other than its own published terms and its own public marketing. Where a clause has a qualifier that softens it, the report says so. Last read Sep 1, 2026.

If you represent Upway and a clause has changed, been withdrawn, or is being read out of context, tell us and we will re-read the documents and update this page. Corrections from the broker are welcome and are published with the reading they change. Contact us.

This is a reading of a contract, not legal advice and not a ruling on Upway. Whether its licence is real and current is a separate check on the broker profile.