GEMINI GALACTIC MARKETS, LLC EXTENDED-HOURS TRADING RISK DISCLOSURE
Effective date: July 13, 2026 | Version: 1.0
Introduction
Gemini Galactic Markets, LLC ("GGM," "we," "our," or "us") may permit eligible customers to enter and execute orders in certain U.S. exchange-listed securities outside regular trading hours. Regular trading hours generally are 9:30 a.m. to 4:00 p.m. Eastern Time ("ET"). Subject to the qualifications below, GGM's extended-hours service is generally available from 4:00 p.m. ET through 9:30 a.m. ET on eligible trading days (the "Extended-Hours Session").
For purposes of this disclosure, the Extended-Hours Session generally consists of:
Post-Market Session: 4:00 p.m. to 7:00 p.m. ET;
Overnight Session: 7:00 p.m. to 8:30 a.m. ET; and
Premarket Session: 8:30 a.m. to 9:30 a.m. ET.
Session availability is subject to market holidays and early closings, the operating calendars and hours of GGM, its carrying broker, applicable execution venues, market-data providers, securities information processors, and trade-reporting facilities, as well as security eligibility, order type, system availability, and applicable law. Hours may change or the service may be suspended because of market, regulatory, technical, operational, or other conditions. Not every security or order type is eligible during every session.
Extended-hours trading involves risks that may be materially different from trading during regular trading hours. This disclosure supplements, and does not replace, the GGM User Agreement, the agreements and disclosures provided by GGM's carrying broker, and any other applicable account agreements and documentation. You should review the following risks before placing an extended-hours order:
1. Risk of Lower Liquidity
There may be fewer market participants and fewer orders available during extended hours than during regular trading hours. As a result, it may be more difficult to buy or sell a security at a competitive price. Your order may be only partially executed or may not be executed at all, even when a displayed price appears to satisfy your order's limit price.
2. Risk of Higher Volatility
Prices may change more rapidly and by larger amounts during extended hours. Lower trading volume and fewer available orders can amplify price movements. You may receive a less favorable execution price than you would during regular trading hours (subject to the price of your limit order), or your order may not be executed.
3. Risk of Changing Prices
Prices during extended hours may differ substantially from a security's official closing price, its price during another extended-hours session, or its price when regular trading begins. A price displayed when you enter an order is not a guarantee of the price at which your order will execute.
4. Risk of Unlinked Markets and Venue-Specific Prices
Extended-hours trading may occur on multiple trading venues that are not linked in the same manner as markets during regular trading hours. A bid, offer, or last-sale price displayed for one venue may not reflect prices available on another venue. You may receive a less favorable price on one venue than was available at the same time on another venue.
Certain order-protection requirements associated with regular trading hours may not apply to transactions executed outside regular trading hours. GGM and the broker responsible for routing and executing customer orders remain subject to applicable best-execution obligations.
5. Risk of News Announcements
Issuers, government agencies, and other organizations frequently release material information outside regular trading hours. Because extended-hours trading may have lower liquidity and higher volatility, news announcements may produce significant or abrupt price movements. Those movements may be exaggerated or may reverse when additional market participants enter the market.
6. Risk of Wider Spreads
The difference between the price at which a security can be purchased and the price at which it can be sold (the bid-ask spread) may be wider during extended hours. A wider spread can increase the cost of entering or exiting a position and may make a displayed last-sale price less representative of the price currently available to you.
7. Market Data Displayed by GGM
Market data displayed by GGM when you view a security or review an order is provided for informational and reference purposes. The market-data product shown may vary based on the time of day and the screen you are viewing. GGM transmits customer orders to Apex Clearing Corporation for routing and execution. A displayed bid, offer, or last-sale price does not determine or guarantee the price at which your order will execute.
During regular trading hours, generally 9:30 a.m. to 4:00 p.m. ET, GGM displays real-time Nasdaq Basic data on the stock-detail screen and current consolidated market data, including the national best bid and offer (“NBBO”), on the order-review screen.
Nasdaq Basic is proprietary, nonconsolidated market data. Its quotation component reflects the best bid and offer available within the Nasdaq market center and does not aggregate quotations from all trading venues. Its last-sale component reflects only the transactions included in the Nasdaq Basic product and is not a consolidated market-wide record of transactions. Nasdaq Basic is not the NBBO.
For market-data display purposes, GGM currently uses the following periods during the Extended-Hours Session:
These market-data display periods are separate from the trading-session and order-eligibility definitions used elsewhere in this disclosure.
During the Delayed Nasdaq Basic Periods, GGM displays Nasdaq Basic data on a fifteen-minute delay. This data is both delayed and nonconsolidated. The displayed Nasdaq bid and offer reflect a historical Nasdaq market-center quotation, not the current NBBO, current market-wide prices, or current market-wide executable trading interest. Because this information is delayed, current quotations, transactions, and liquidity on Nasdaq may differ materially from the displayed information. Because it is nonconsolidated, prices and liquidity available on other trading venues may also differ materially. The displayed timestamp identifies the time to which the information relates. Additional delays, interruptions, or failures may occur because of vendor, communications, network, or system conditions.
During the Bruce Data Period, GGM displays Bruce BBO and Bruce Last Sale data originating from Bruce ATS and distributed by Nasdaq without an intentional delay. Bruce BBO reflects only the best displayed bid and offer on Bruce ATS. Bruce Last Sale reflects only transactions executed on Bruce ATS. Neither data product is a consolidated market display or the NBBO, and neither reflects quotations, transactions, sizes, or liquidity available on other trading venues. Prices available elsewhere may differ, and a better price may be available on another venue. The transmission of Bruce data without an intentional delay is described as “real-time.” However, it does not guarantee that a displayed price is currently executable, that Bruce ATS is then accepting or executing orders, or that the most recent Bruce transaction occurred recently. A last-sale price represents a previously completed transaction; it is not an offer to buy or sell a security and does not establish the price at which your order will execute.
The GGM trading interface identifies the applicable market-data product and source, whether the information is real-time, delayed, stale, last available, or unavailable, the applicable delay interval, and the time to which the displayed information relates. Because different market-data products may be displayed at different times or on different screens, a price shown on the order-review screen may differ from a price previously shown on the stock-detail screen.
During the Extended-Hours Session, the market data displayed by GGM is not a consolidated market-wide display and does not reflect the NBBO. Market data may become delayed, interrupted, stale, unavailable, or erroneous because of venue, vendor, communications, network, or system conditions. Information identified as delayed, stale, prior-session, last available, indicative, or unavailable should not be relied upon as reflecting current executable trading interest.
During extended hours, GGM accepts only limit orders. You should select your limit price based on the highest price you are willing to pay for a purchase or the lowest price you are willing to receive for a sale, rather than relying solely on displayed market data.
8. Risk of Delayed and Nonconsolidated Market Data
During certain portions of the Extended-Hours Session, GGM displays market data that is delayed and nonconsolidated. This information does not reflect current market conditions, the current NBBO, or current executable trading interest across the market.
The current bid, offer, last-sale price, available size, and liquidity may differ materially from the information displayed by GGM. Prices available on another trading venue may also differ from the delayed Nasdaq information displayed by GGM.
As a result:
your limit order may execute even though the displayed data appears to indicate that your limit price is not currently executable;
your limit order may not execute even though the displayed data appears to indicate that your limit price could be executed;
your order may execute at a price materially different from the displayed last-sale price, although a buy limit order will not execute above its limit price and a sell limit order will not execute below its limit price; and
an All Sessions order may execute during a later session under market conditions that differ materially from those reflected in the data displayed when you entered the order.
You should select a limit price based on the highest price you are willing to pay or the lowest price you are willing to receive, rather than relying solely on displayed market data.
Market data may also become interrupted, stale, or unavailable. Information identified as “last available,” “prior session,” or similar is not a current quotation or an indication of currently executable trading interest.
9. Differences in Order Types, Routing, and Order Handling
GGM currently supports market orders and limit orders. Market orders are accepted only during regular trading hours and are not eligible for execution during any Extended-Hours Session. During extended hours, GGM accepts only limit orders.
A limit order controls the maximum price you are willing to pay for a purchase or the minimum price you are willing to receive for a sale, but it does not guarantee that your order will execute. A limit order may be partially filled, rejected, canceled, or expire without execution.
When you place a limit order during regular trading hours, the default will be that the order will persist during all trading sessions and will remain good-until-cancelled for a max duration of 360 calendar days. Gemini intends to add the functionality that will enable you to designate the order as market hours only (9:30 a.m. ET to 4:00 p.m. ET) for the current trading day. An order designated as market hours only is eligible for execution only during regular trading hours and will not execute during an Extended-Hours Session. An all-sessions limit order, the default, is eligible for execution during regular trading hours and each available Extended-Hours Session and remains eligible as trading transitions from one session to another, subject to the order’s applicable time-in-force and the other conditions described in this disclosure.
A limit order entered during any Extended-Hours Session is treated as an all-session limit order. Unless it is filled, cancelled, rejected, or expires, the order remains eligible for execution during subsequent extended-hours sessions and during regular trading hours when they resume.
An all-sessions order, or any unexecuted portion of it, may execute at any time during a session for which it is eligible, including after a material price movement or news announcement and while you are not monitoring your account. A partial execution does not, by itself, cancel the unexecuted portion of the order. You should cancel or modify an open order if you no longer want it to remain eligible for execution in a later session.
A request to cancel or modify an order is not effective until cancellation or modification is confirmed. Your order may execute while a cancellation or modification request is pending. An order sent to an execution venue may be subject to that venue's own acceptance, display, execution, cancellation, expiration, price-band, routing, and other rules.
The market-data source displayed by GGM may differ from the execution venue to which an order is routed. As trading moves between sessions, GGM, its carrying broker, or an executing broker may use different execution venues or take other order-handling steps necessary to maintain the customer order’s eligibility across sessions. Customer-level persistence does not necessarily mean that the same venue-specific order remains continuously open on a single execution venue.
10. Price Bands, Trading Halts, and Other Controls
An execution venue may apply price bands or other controls based on a reference price established before or during the applicable session. An order outside an applicable price band may be rejected, canceled, prevented from being displayed, or unable to execute. A reference price or price band may not reflect significant news or price movements that occur after it is established.
An execution venue, GGM, or GGM's carrying broker may restrict or halt trading, reject orders, or cancel open orders because of market conditions, regulatory action, corporate actions, risk controls, technical problems, or other circumstances. These controls may differ from controls applicable during regular trading hours and do not guarantee that an execution price will be fair or competitive.
11. Corporate Actions and Reference Prices
Stock splits, dividends, mergers, symbol changes, and other corporate actions may affect a security, a displayed reference price, or an open order during extended hours. Relevant adjustments may not be reflected immediately in every displayed price or reference price. GGM, its carrying broker, or an execution venue may adjust, reject, or cancel affected orders.
12. Exchange-Traded Products
Exchange-traded funds and other exchange-traded products may trade at a significant premium or discount to the value of their underlying holdings during extended hours. The underlying securities, indexes, net asset values, or indicative values used to value an exchange-traded product may not be trading, calculated, or updating during all extended-hours sessions. This can make the product more difficult to value and can increase volatility and spreads.
13. Fractional-Share Orders
Fractional-share orders are not eligible during the Extended-Hours Session.
14. Systems, Communications, and Customer Support
Electronic trading systems, market-data services, execution venues, communications networks, and third-party providers may experience delays, interruptions, or failures. These conditions may prevent or delay your ability to enter, modify, or cancel an order or to receive current information about an order.
An order may execute while you are unable to access your account or while market data is unavailable. Customer support and backup trading arrangements may be more limited during overnight hours than during regular business hours. Gemini customer support operates 24/7 and can be reached through our Support Centeror via an email to support@gemini.com. 15. Security and Account Eligibility
GGM may limit which securities, accounts, order types, or account features are eligible for extended-hours trading and may change eligibility at any time. GGM does not support margin orders, options orders, or short-sale orders during the Extended-Hours Session.
Acknowledgment
You acknowledge that GGM has furnished this Extended-Hours Trading Risk Disclosure to you and that you have had an opportunity to review it before using GGM's extended-hours trading service. Your acknowledgment does not waive any right or protection provided by applicable law.
