This Promotion Policy (hereinafter referred to as the "Policy") defines the terms and conditions for the "Black Friday Cashback" promotion (hereinafter referred to as the "Promotion"). This document has been developed in compliance with the current legislation of the European Union and Canada regarding consumer protection, advertising, and personal data processing, including, but not limited to, the Unfair Commercial Practices Directive (2005/29/EC, as amended), the General Data Protection Regulation (GDPR, (EU) 2016/679), and the Competition Act of Canada (R.S.C., 1985, c. C-34).
Participation in the Promotion constitutes the Participants' full and unconditional agreement to this Policy. This Promotion is a cashback loyalty program and is not a lottery, game of chance, or a risk-based contest.
All verified users of the KEYTOM service who are holders of a Keytom Virtual Card are eligible to participate in the Promotion (hereinafter referred to as "Participants").
Transactions made outside this period are not eligible for the Promotion.
4.1. During the Promotion period, Participants will receive a 10% cashback on the amount of each eligible purchase made with the Keytom Virtual Card.
4.2. The maximum total cashback amount that a single Participant can earn during the entire Promotion period is 300 USDC (three hundred US Dollars in the USD Coin stablecoin).
4.3. Cashback is calculated automatically based on transaction data. The accumulated cashback amount will be paid out to all eligible Participants in a single payment on December 1, 2025, to their balance in the KEYTOM system.
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6.1. The Organizer is not liable for any technical failures, software errors, communication problems, or other issues that may affect participation in the Promotion or cashback calculation, unless caused by the Organizer's willful misconduct or gross negligence.
6.2. Participants are solely responsible for the payment of any applicable taxes and fees that may arise in connection with receiving cashback, in accordance with the laws of their jurisdiction.
6.3. Cryptocurrency Disclaimer: Participants acknowledge and understand that the value of cryptocurrency assets, including stablecoins, can be volatile. The Organizer does not provide any financial advice and is not responsible for the financial risks associated with owning and using USDC.
7.1. For the purposes of conducting the Promotion, including calculating and paying out cashback, the Organizer processes the personal data of Participants (including user ID and transaction data). The legal basis for such processing is the performance of the user agreement and the consent to participate in the Promotion, expressed by making eligible transactions during its period.
7.2. Data processing is carried out in strict accordance with the General Data Protection Regulation (GDPR) and the Company's main Privacy Policy. Participants have the right to access, rectify, erase, and restrict the processing of their data.
7.3. By participating in the Promotion, the Participant confirms that they have read and agree to the terms of their personal data processing for the purposes of this Promotion.
This Policy is governed by and construed in accordance with the laws of the jurisdiction in which Keytom Services Ltd. is registered. All disputes and disagreements arising in connection with the Promotion shall be resolved through negotiation. If an agreement cannot be reached, the dispute may be referred to a competent court at the Organizer's place of registration.
Notwithstanding the foregoing, this Policy is intended to comply with the mandatory consumer protection laws of the European Union and Canada that may apply to Participants from these regions.
For more information or in case of questions, Participants can contact KEYTOM support through the official communication channels listed on the Company's website: www.keytom.com.
References to Regulatory Acts:
1 Competition Act (R.S.C., 1985, c. C-34)
2 Unfair Commercial Practices Directive (2005/29/EC)
3 General Data Protection Regulation (GDPR, (EU) 2016/679)
4 Directive (EU) 2019/2161 on better enforcement and modernisation of Union consumer protection rules