1. Comprehensive Executive Summary & Regulatory Stance
This document constitutes a binding and comprehensive statement of technical architecture, legal boundaries, and regulatory compliance for the ZTEN System Platform (hereinafter referred to as "ZTEN", "Platform", "Software", or "System"). ZTEN is an independently developed, Python-based, open white-box software platform designed exclusively to allow financial researchers, software engineers, and derivative traders to design, configure, backtest, and forward-simulate rule-based options trading strategies. These strategies include, but are not limited to, Iron Condors, Bull Put Spreads, Bear Call Spreads, Straddles, and Strangles.
ZTEN has been engineered from the foundational architecture upwards to comply strictly and unambiguously with all applicable statutory provisions, regulatory frameworks, press releases, circulars, and guidelines established by the Securities and Exchange Board of India (SEBI), the National Stock Exchange of India Limited (NSE), the BSE Limited (BSE), and all relevant regulatory agencies governing capital markets in India.
PRIMARY MANDATORY COMPLIANCE DECLARATION: ZTEN is NOT a broker-dealer, NOT an investment adviser, NOT a research analyst, NOT a portfolio manager, NOT an asset management company, and NOT a SEBI-registered intermediary. ZTEN does NOT redistribute live exchange data to the public, does NOT execute real-market automated transactions on behalf of third parties, does NOT provide financial recommendations or stock tips, does NOT guarantee financial returns, and does NOT host real-time market-fed gaming or paper-trading competitions. All public, shared, or non-authenticated dashboard functions operate on offline, static, synthetic, or datasets delayed by a minimum of 30 days.
2. Multi-Layer Operational Architecture & Technical Boundary Conditions
ZTEN strictly segregates its software architecture into distinct execution modes to guarantee that public analytical dashboards never infringe upon exchange intellectual property rights or violate SEBI guidelines regarding live-feed paper trading.
| Architectural Parameter |
Public / Shared Dashboard Mode (Offline View) |
Private BYOK Forward Simulation Mode |
| Data Source & Feed Type |
Offline Static Databases & Historical Exchange Records |
Direct Broker Session (User Personal API Ticker) |
| Data Latency / Age |
Minimum 30-Day Delay / Historical Static Snapshots |
Client-Side Private Session Feed (Zero Central Redistribution) |
| Execution Destination |
Isolated Virtual Database (In-Memory Paper Ledger) |
Isolated Virtual Database (In-Memory Paper Ledger) |
| Central Server Streaming |
None (Static JSON / Historical Pre-Rendered Charts) |
None (Peer-to-Client Local Session Only) |
| Target Audience |
Unauthenticated Public / Analytical Audience |
Authenticated Individual Account Holder Only |
| Regulatory Classification |
Educational Software & Strategy Calculator |
Client-Side Private Execution Utility Tool |
3. Regulatory Declarations
3.1. Compliance with SEBI Press Release No. 37/2024 & Anti-Gaming Directives
SEBI Press Release No. 37/2024 explicitly restricts platforms from offering public, real-time virtual trading games, paper-trading leagues, or live market-fed simulation software that mimics live execution without proper registration. ZTEN adheres strictly to this directive:
- No Public Live-Feed Paper Trading: Public or third-party users viewing the ZTEN platform cannot access real-time market pricing or live Last Traded Price (LTP) tickers.
- Synthetic & 30-Day Delayed Framework: Any public-facing strategy testing, performance visualization, or strategy outcome model hosted on the ZTEN dashboard utilizes historical market data carrying a compulsory lag of at least 30 days or synthetically constructed pricing models.
- No Competitive Gamification or P&L Leaderboards: ZTEN strictly refrains from organizing trading contests, virtual prize pools, rank-based leaderboards, or commercial paper-trading leagues based on live market movements.
3.2. Compliance with SEBI Algorithmic Trading Frameworks
Regarding SEBI circulars governing algorithmic trading mechanisms and automated execution utilities:
- Complete White-Box Transparency: ZTEN is strictly a "white-box" tool. All underlying decision logic, leg delta calculations, entry timestamps, exit percentages, stop-loss triggers, trailing conditions, and wing adjustments are completely visible, exposed, and modifiable by the end-user.
- No Black-Box Proprietary Algorithms: ZTEN does not market, distribute, or execute undisclosed, proprietary "black-box" trading algorithms that hide their underlying execution logic from the operator.
- No Unapproved Broker-API Routing: ZTEN does not bypass broker risk management systems (RMS). It does not maintain direct OMS (Order Management System) or EMS (Execution Management System) connections to exchange gateways without passing through an accredited broker's approved API infrastructure.
3.3. Exchange Intellectual Property & Market Data Redistribution Compliance
In accordance with the market data vendor agreements and intellectual property policies of the NSE, BSE, and brokerage API terms (such as Zerodha Kite Connect):
- Bring Your Own Key (BYOK) Operational Isolation: Whenever an individual user chooses to perform forward simulation or paper testing against live market conditions, the user must supply their own individual, legally obtained broker API credentials (e.g., Kite Connect API Key and Access Token).
- Prohibition of Master-Key Redistribution: ZTEN does not maintain, utilize, or operate a centralized "Master API Key" to fetch live tick data and stream, re-broadcast, or distribute it to multi-tenant unauthenticated third parties.
- No Unlicensed Commercial Data Reselling: ZTEN does not store, re-package, or commercialize exchange market data for third-party resale, fulfilling all exchange data ownership mandates.
3.4. Complete Exemption from SEBI (Investment Advisers) & (Research Analysts) Regulations
ZTEN operates entirely outside the domain of investment advisory or equity research services:
- Non-Advisory Status: ZTEN does not evaluate individual user financial profiles, risk capacities, or investment goals. It provides no personalized or generalized financial advice, trade signals, or investment allocations.
- User-Configured Parameters: Every paper-trade entry, strike selection, delta threshold, and exit trigger executed within the ZTEN simulation engine is the sole creation and technical input of the user.
- No Performance Guarantees or Profit Sharing: ZTEN does not offer profit-sharing models, portfolio management services (PMS), alternative investment funds (AIF), or guarantees of strategy profitability.
4. Complete Terms of Use, Technical Limitations, & Legal Disclaimers
All users accessing, loading, embedding, or using the ZTEN platform, dashboard, or associated Python codebases explicitly agree to the following legally binding terms:
- Educational & Research Purpose Only: The ZTEN platform is provided strictly "as-is" and "as-available" for educational, analytical, and technical strategy research. It does not constitute an offer, solicitation, or recommendation to buy or sell securities, options, or derivative instruments.
- Virtual Ledger Mechanics: All trade outcomes, profit and loss (P&L) statements, win rates, drawdowns, and performance metrics displayed within the ZTEN environment represent hypothetical paper trades calculated within a local virtual database. No real money is spent, and no financial orders are transmitted to exchange matching engines.
- Inherent Limitations of Paper Trading & Backtesting: Hypothetical or simulated performance outcomes carry severe structural limitations. Paper-trading engines do not simulate real-market dynamics, including order queue delays, market impact, bid-ask spread expansion during volatility spikes, exchange system outages, margin call rejections, or execution slippage. Actual live trading may yield significantly different performance results.
- Data Delay Acknowledgment: Users explicitly acknowledge that all public metrics, strategy renders, and shared dashboards operate on non-live datasets delayed by a minimum of 30 days or generated offline. Users desiring real-time forward testing must execute local sessions via their own broker credentials under full personal responsibility.
- Complete Limitation of Liability: Under no circumstances shall the developers, authors, operators, or distributors of ZTEN be held liable for any direct, indirect, incidental, consequential, special, or exemplary damages, including financial trading losses, lost profits, capital erosion, system failures, or data loss arising from the use or misuse of this software.
5. Platform Verification, Sign-Off, & Metadata
This document serves as the permanent legal and regulatory compliance reference for the ZTEN System Platform. It must remain accessible on all public-facing dashboards, documentation sites, and user onboarding flows associated with ZTEN.
System NameZTEN Strategy Engine & Rules Simulation Platform
Compliance StatusFully Compliant (SEBI PR 37/2024, White-Box Architecture, 30-Day Delayed / BYOK Simulation Engine)
Document Hash / VersionZTEN-COMP-FULL-2026-V3
Effective DateSeptember 7, 2026