§ 1

General provisions

1. These Regulations set out the rules of participation, including listing the conditions that must be met in order to participate in the Contest "ZND - Loyalty Week with ZND" (described in § 3 et seq. of these Regulations, hereinafter: "Contest") and the Promotional Action "ZND - Loyalty Week with ZND" (described in § 2 of these Regulations, hereinafter: "Promotional Action").

2. The Contest Organizer and the Promotional Action is: BB Trade Estonia OÜ with its registered office in Harju maakond, Tallinn, Lasnamäe linnaosa, Tähesaju tee 9, 1391 Estonia (office number 10), registered in the Register of Entrepreneurs under the number 14814864, which is the operator of the zondacrypto exchange, and ZND.CO OÜ with its registered office in Tallinn at: Harju maakond, Tallinn, Lasnamäe linnaosa, Tähesaju tee 9, 13917, Estonia (hereinafter: "Organizer").

3. The tasks of the Contest Organizer include the day-to-day supervision of the Contest and the Promotional Action, including, in particular, determining whether there is any risk of violating the Contest or Promotional Action rules, as established by these Regulations, in connection with the Contest or the Promotional Action. 

4. The Contest Organizer also uses in these Contest and Promotional Action Regulations (hereinafter: "Regulations") definitions consistent with those contained in the regulations available at https://zondacrypto.com/en/legal/zondacrypto-exchange and https://znd.co/, the contents of which are hereby referred to in this respect. If the provisions of the aforementioned regulations conflict with these Regulations, the provisions of these Regulations shall apply. Being a user of the zondacrypto Platform and the ZND Platform, the Contest Participant is obliged to apply the regulations of both these Platforms, in accordance with their provisions. 

5. The Contest is held in connection with the Contest Organizer's event of organizing the ZND Promotional Action - Loyalty Week with ZND on the Contest Organizer's Platforms, during which Loyalty Points earned from activity resulting from transactions in the Trade service on the ZND Platform and from transactions on the zondacrypto Platform will give 3x more Loyalty Points. Details of the Promotional Action are described in § 2 of these Regulations.

6. The place of sharing the Contest and the Promotional Action is the following social media: Facebook, X (Twitter) (hereinafter: "Social Media"), on the following indicated profiles/channels belonging to the Organizer:

1. Facebook: https://www.facebook.com/zondacryptopolska; https://www.facebook.com/zondacrypto; 

2. X (Twitter): https://x.com/zondacryptopl, https://x.com/zondacrypto, https://x.com/ZND_co.

7. The Contest and the Promotional Action are aimed at users of the Organizer's Platforms who:

• have registered and verified their client/user accounts on the Organizer's zondacrypto Platform: https://www.zondacrypto.com (hereinafter: "zondacrypto Platform") and ZND Platform: https://znd.co (hereinafter: "ZND Platform"); (collectively, the "Platforms"); or 

• already had registered and verified client/user accounts on the Platforms prior to the start of the Contest,

• and are actively participating in the ZND Loyalty Program on the ZND Platforms or have joined the ZND Loyalty Program as part of the Contest or Promotional Action.

8. The Contest Organizer emphasizes that neither the Contest nor the Promotional Action is co-created, administered or sponsored by the above mentioned Social Media.

9. The Contest Organizer is the sole funder of the Contest Prizes.

10. Neither the Contest nor the Promotional Action is a cash lottery, a sweepstakes, a promotional lottery, or any other game of chance or betting game.

 

§ 2

ZND Promotional Action - Loyalty Week with ZND.

1. The Promotional Action "ZND - Loyalty Week with ZND" lasts from July 23, 2025 from its publication on Social Media until August 6, 2025 at 23:59 CET.

2. The Promotional Action is open to all users who are of legal age (18 years of age or older), have a registered and verified client/user account on both Platforms, and who actively participate in the ZND Loyalty Program on the ZND Platform, the regulations of which can be found at: https://assets.znd.co/agreements/en/loyalty-program-agreement.pdf and to which the Organizer hereby refers.

3. As part of the Promotional Action, throughout its duration in accordance with paragraph 1 above, participants in the ZND Loyalty Program referred to in § 2(2), receive triple the amount of Loyalty Points for Activities resulting from:

   1. completing transactions in the Trade service on the ZND Platform (Activity: "30-day Transaction Volume on zondacrypto");

   2. completing transactions on the zondacrypto Platform (Activity: "Transaction volume in the Trade service").

The default value of Loyalty Points for the Activities described above, which a Loyalty Program participant gets according to the ZND Loyalty Program Activity Table (available at: https://assets.znd.co/loyalty/en/activities-table.pdf, will be multiplied by a multiplier of x3 (three) during the Promotional Action.

4. Multiplied Loyalty Points earned under the Promotional Action will be added to the user's account within 5 business days from the date the Promotional Action ends.

5. According to the regulations of the ZND Loyalty Program, Loyalty Points are awarded for a period of 90 days from the date of award. Detailed terms and conditions of the ZND Loyalty Program can be found at: https://assets.znd.co/agreements/en/loyalty-program-agreement.pdf.

 

§ 3 

Participation in the Contest

1. The Contest is intended for natural persons - users of the Contest Organizer's Platforms who are of legal age (18 years of age or older), have a registered and verified client/user account on both Platforms, and who actively participate in the ZND Loyalty Program on the ZND Platform. 

2. A participant in the Contest (hereinafter: "Participant") is a person who has met all the requirements indicated in § 3 and § 5 of these Regulations together, and who has active and verified accounts on the Platforms and actively participates in the ZND Loyalty Program.

3. By completing the registration and verification of client/user accounts on the Platforms, as indicated in § 3(1) above, it is understood that the Participant has accounts on the Platforms and successfully completes the authentication process (KYC) by correctly passing all its stages. The Contest Organizer allows Participants to create client/user accounts on the Platforms and pass the KYC process during the Contest, but no later than at the end of the Contest in accordance with § 4(1) of the Regulations.  The Organizer will verify the fulfillment of the above criterion by checking whether the Participant has active and verified client/user accounts on the Platforms as of the aforementioned moment. In the event that the above requirement is not met, the Organizer reserves the right to refuse to award the Prize to a given Participant. At the same time, the Contest Organizer stipulates that meeting this requirement after the Contest begins may deprive the Participant of the possibility of completing some Contest Tasks that are related to taking actions on the Platforms (including participation in the ZND Loyalty Program). 

4. The Contest can only be participated in person, and therefore it is not permitted to submit entries to the Contest on behalf of third parties. Identity and other information about the Participant should be consistent with the data (including personal information) indicated in the Contest and during the process of registration and verification of the Participant's identity on the Platforms. The Contest Organizer reserves the right to verify, including verification of the identity of Contest Participants, and in case of reasonable doubt as to whether the aforementioned conditions are met, to possibly refuse to award the Contest Prize to a Participant on this basis. 

5. Employees, members of the authorities and representatives of the Contest Organizer and other entities directly involved in the preparation and execution of the Contest, as well as persons permanently cooperating with the above-mentioned entities on a basis other than an employment relationship, and members of their immediate families, i.e. ascendants, descendants, siblings, spouses, parents of spouses and persons in an adoption relationship with them, may not participate in the Contest.

6. The condition for participation in the Contest is acceptance of the content of these Regulations and willingness to participate in the Contest by making a Contest application and completing the Contest Tasks along with meeting the requirements of the Regulations, as indicated in § 4 and § 5 below. 

7. The Participant entering the Contest in accordance with the preceding paragraphs is obliged to familiarize himself with the provisions of the Regulations. Entering the Contest implies acceptance of the terms of these Regulations.

8. Participation in the Contest is completely voluntary and free of charge. 

9. Participation in the Contest and related sharing of personal data is completely voluntary, based on the Participant's consent - in accordance with § 10(2)(a) of these Regulations.

10. By accepting the Regulations, in the event of winning the Prize referred to in § 6 below, the Participant agrees to publish his/her name and surname or nickname used in Social Media as part of a possible post/announcement created by the Contest Organizer regarding the conclusion of the Contest and the selection of the Winner on the Contest Organizer's Social Media profiles, including the created ranking of the Winners. 

11. At the same time, by accepting the Regulations, the Participant agrees to the publication of his/her name and surname or nickname, used in Social Media in the form of a partially anonymized ranking of the Winners of the ZND Loyalty Points earned by the Participants. 

 

§ 4 

Duration of the Contest

1. The Contest runs from July 23, 2025, from its publication on Social Media, until August 6, 2025, 23:59 CET. 

2. The Contest will be resolved within 14 days after its conclusion, with the announcement of the Winners scheduled for August 20, 2025. The Contest Winner will be notified of the win on that date by the Contest Organizer publishing the winning post informing on the Contest Organizer's Social Media as indicated in § 1(6) of the Regulations and on zondacrypto's blog or by a private message from the Contest Organizer. 

3. The Prize in the form of ZND Tokens will be awarded to the Winners within 30 days after the announcement of the list of Winners, by adding them to the Winner's wallet address on the ZND Platform, taking into account the 30-day vesting (consisting of the gradual awarding of the Prize to the Winner during this period, in proportion to the number of days of vesting and the amount of the Prize awarded).

4. The Prize in the form of a T-Shirt and Tickets will be sent to the Winner of the Contest within 30 days of the announcement of the results, subject to § 6(3-4) of the Regulations.

 

§ 5 

Rules of the Contest

1. The Contest Task (hereinafter referred to as the "Contest Task") consists in the Participant's earning of the highest possible number of Loyalty Points obtained for performing specific activities, i.e. activating subscriptions in the Earn service on the ZND Platform exclusively on the cryptoassets listed below:

   1. Bitcoin (BTC);

   2. Ethereum (ETH);

   3. Ripple (XRP).

Loyalty Points earned in accordance with § 5(1) are awarded on the basis of the ZND Loyalty Program Activity Table, which is available at: https://assets.znd.co/loyalty/en/activities-table.pdf.

2. The detailed rules of the ZND Earn service referred to in paragraph 1 above are available in the Regulations of the Earn service, available on the ZND Platform at: https://assets.znd.co/agreements/en/earn-terms-and-conditions-19-07-2025.pdf, to which the Organizer hereby refers.

3. The Contest is open, i.e. any person who meets the requirements specified in the Regulations may enter.

4. The Contest Task may be performed only during the Contest Period indicated in § 4.1 of the Regulations. Completion of the Contest Task after the time mentioned above will not be taken into account by the Organizer. 

5. The Contest Entries will be judged by the Contest Commission (hereinafter referred to as the "Commission"), consisting of representatives of the Organizer and persons designated by the Organizer, as specified in § 8 of the Regulations.

6. At the end of the Contest, the Commission will select from among the Participants ten (10) winners who have correctly completed the Contest Tasks specified in § 5.1 of the Regulations, and who have earned the most Loyalty Points for completed Activities described in § 5.1 during the Contest Period (hereinafter referred to as "Winners", and individually as "Winner"). 

7. In the Contest, the Winners, depending on their place, will be awarded the Prizes described in § 6 of the Regulations (hereinafter: "Prize").

8. In determining the Winners, the Contest Commission shall at the same time decide whether to award a given Prize in the Contest to a given Winner, following the criteria described in the Regulations and verifying the Winner's fulfillment of the conditions set forth in the Regulations. Failure to meet these conditions may result in the exclusion of such Participant from the Contest and the awarding of the Prize to another Participant, and may also decide to forfeit the Prize to the Contest Organizer (if there are no Participants who meet the conditions for awarding the Prize).

9. The Contest Organizer reserves the right to exclude Participants from the Contest or deprive them of the right to the Prize - also after the Contest has ended - Participants whose activities violate the law, good morals or the Regulations, in particular Participants who do not act personally, but through third parties, and use different accounts on the Platforms to act on behalf of the same Participant.

10. In order to clarify doubts related to the Participant's activity in the Contest, the Organizer may contact the Participant through the means of communication used by the Participant. During such contact, the Organizer may expect the Participant to provide detailed information regarding his/her participation in the Contest.

11. Once the Contest Organizer has determined the information regarding the Contest Winners and positively verifies that they meet the Contest requirements, the Prize will be transferred to them, at the time and in accordance with the terms and conditions indicated in § 4 paragraphs 3-4 and § 6 of these Regulations.

12. The winner of the Contest will be announced by posting the winning post in the aforementioned Contest Organizer's Social Media and on the zondacrypto blog, indicating the first part of the email address assigned to the Winners' account on the Organizer's Platforms. When announcing the results, the Organizer will ask the Winner to contact him via email. Once contact is made, the Organizer will provide further instructions in order to ascertain all data necessary to send the Winner the Prize and to enable the Winner to properly use it.

13. The 1st place Winner, in order to claim the prizes in kind referred to in Paragraph 6, Paragraph 1, i.e. the T-Shirt and the Ticket, is obliged to respond to the Organizer's email no later than 7 days after the first email from the Organizer, under pain of complete forfeiture of the right to the Prize. Failure to contact the Organizer within this timeframe shall be tantamount to the possibility of selecting another Winner, who will receive the above-described prizes in kind, while this is reserved as a right and not an obligation of the Organizer.  

14. The Contest Organizer reserves the right to exclude from participation in the Contest or deprive of the right to the Prize Participants whose actions are contrary to the law, good morals or the Regulations, in particular Participants who:

• do not act personally, but through third parties;

• use different accounts on the Organizer's platform to act on behalf of/apply for the same Participant;

• come from a country/region not supported by the zondacrypto cryptocurrency exchange.

 

§ 6

Prizes

1. The following prizes (hereinafter referred to as "Prizes") will be awarded in the Contest, depending on the place taken:

1. for placing 1st - the equivalent of $750 in ZND Tokens to be allocated to the balance in the Client's ZND Account on the ZND Platform (hereinafter referred to as "ZND Tokens"), a match shirt of the Winner's choice of a zondacrypto-sponsored club (hereinafter referred to as "Shirt"), and 1 double admission ticket to the selected match of a zondacrypto-sponsored club, as agreed with the Organizer (hereinafter referred to as "Ticket"); 

2. for placing 2nd - the equivalent of $450 in ZND Tokens;

3. for placing 3rd - the equivalent of $250 in ZND Tokens;

4. for placing 4th-6th - the equivalent of $100 in ZND Tokens;

5. for placing 7th-10th - the equivalent of $50 in ZND Tokens. 

2. The prize of ZND Tokens will be awarded to the Winner within 30 days of the announcement of the list of Winners, by adding them to the Winner's wallet address on the ZND Platform, taking into account the 30-day vesting (consisting of the gradual awarding of the Prize to the Winner during this period, in proportion to the number of days of vesting and the amount of the Prize awarded).

3. The number of ZND Tokens to be vested as part of the Prize will be determined based on the opening price ZND Token price in USD as of the date of the Winner's post referred to in § 4(2) of the Regulations, according to the ZND Token exchange rate indicated on Coin Market Cap: https://coinmarketcap.com/currencies/znd-token/historical-data/. This rate will be used to determine the number of ZND Tokens as of the date they are assigned to the Winner's account as part of the vesting commencement described in paragraph 2 above, and consequently, this rate is subject to change during the vesting process.

4. The Organizer does not guarantee any exchange rates for ZND Token. The value of ZND Tokens at the time of vesting or at any future date may differ from the valuation at the time of transfer.

5. The prize in the form of a T-Shirt and Tickets will be sent to the Contest Winner within 30 days after providing the details indicated in paragraph 4 below. The Prize will be sent to the Winner by snail mail, to the Winner's address indicated by the Winner in his/her private contact with the Organizer, in accordance with § 4(11-12) of the Regulations. 

6. The Winner who takes the 1st place, in order to be eligible for the Prize in the form of a T-Shirt and Tickets, as indicated in paragraph 1 above, is obliged to send in a private message to the Organizer, as indicated by the Organizer, all data necessary for the transfer of the Prize to him/her, i.e., in particular:

   1. first and last name, 

   2. shipping address, 

   3. email, 

   4. telephone number,

   5. date of birth,

   6. PESEL, and in case it has not been assigned - type, series and number of identity document.

In the event of failure to comply with the above information obligation within the time limit specified above in § 5(13), the Winner will forfeit the right to the Prize in the form of a T-Shirt and a Ticket. In such case, the Organizer reserves the right to award the Prize to the next Participant, selected by the Contest Commission.

7. In the event that the Prize of the Winner is a double ticket, referred to in § 6(1)(a) of the Regulations, the Winner has the right to freely choose an accompanying person who will use the double ticket together with the Winner (hereinafter: "Accompanying Person") - provided that the requirements specified below are met.

8. The Accompanying Person must be a person of legal age (who is at least 18 years old), who is a resident of the Republic of Poland.

9. The Winner, in order to be eligible for the Prize in the form of a Ticket, referred to in § 6(1)(a) of the Regulations, is obliged to send in a private message to the Organizer, as indicated by the Organizer, the data of the Companion necessary for the transfer of the Prize to him/her, viz:

   1. first and last name of the Companion,

   2. Date of birth of the Companion Person,

   3. PESEL of the Companion Person, and in case it has not been assigned - the type, series and number of the document confirming the identity of the Companion Person.

If the above information obligation is not fulfilled within the time limit specified above, the Winner will lose the right to choose the Companion. 

10. The Organizer reserves the right to verify the Companion and the compliance of the data provided by the Winner, and in case of reasonable doubts regarding the fulfillment of the above-mentioned conditions - to deny the Winner the right to choose the Companion, if any.

11. The Organizer does not cover additional costs related to the collection and use of the Prizes, such as costs of travel, cabs, meals and other incidental costs. These costs shall be borne entirely by the Winner and he/she is not entitled to reimbursement from the Organizer in this respect.

12. The Organizer informs that the condition for awarding the Prizes is that on the date of said award the Participant's account on the Platforms (ZND and zondacrypto, respectively) is fully verified, participation in the ZND Loyalty Program and compliance of his/her actions with the regulations.  

13. The Organizer does not make any guarantee regarding the value of the ZND Token.

14. Receipt of Prizes under the Contest does not require Participants to make any purchase or payment for the Prizes assigned to him/her, including ZND Tokens. The Organizer does not charge any fee and/or commission for assigning ZND Loyalty Points or ZND Tokens to a Participant's wallet. The above applies only to the one-time award of ZND Loyalty Points and ZND Tokens to the Participant in the Contest and does not apply to the Participant's subsequent independent actions on his/her account, including those related to the ZND Token. 

15. If the Winner submits an instruction to close the Client's Account on the Organizer's Platform before the ZND Tokens are awarded, the Winner will lose the right to ZND Tokens. In such case, the Organizer reserves the right to award the prize to the next Participant selected by the Contest Commission.

16. The Organizer stipulates that the number of Prizes may be changed in favor of the Winners (by awarding additional prizes). 

17. One Winner of the Contest is entitled to only one Prize, depending on the place taken.

18. The Winner may be required to provide the Contest Organizer in a private message with all data, required by the Contest Organizer, necessary to determine the ownership of the accounts on the Platforms, in accordance with § 3 of these Regulations, in order to correctly assign the Prize to the Winner, as well as other data necessary to determine the Winner's correct participation in the Contest.

19. In the event that the above information obligations are not fulfilled within the timeframe specified by the Organizer, the Winner may forfeit the right to the Prize. In such case, the Organizer reserves the right to award the Prize to another Participant, selected by the Contest Commission. 

20. It is not possible to transfer the right to the Prize to third parties. It is not possible to pay the equivalent of the Prize in any FIAT currency or cryptocurrency. 

21. It is possible to resign from the Prize by submitting an appropriate statement to the Organizer at the e-mail address [email protected]. In the case of resignation of the Winner from the Prize, the Organizer reserves the right to award the Prize to another Participant.

 

§ 7

Organizer's Liability

1. The Organizer shall not be liable for the inability to transfer the Prize to the Winner, as well as to the Companion, and the realization of the Prize for reasons beyond the Organizer's control, including in connection with the provision of incorrect contact information, the lack of positive verification of the Participant (KYC), as well as in connection with force majeure events. In such a case, the Winner will be informed of the aforementioned circumstances in a private message or will be asked to contact the Organizer via email. 

2. The Organizer is not responsible for fortuitous events preventing the Participants from taking part in the Contest.

3. The Organizer is not responsible for the inability of the Participants to achieve the expected results of making transactions on the Platforms due to reasons attributable to the Participants.

4. The Organizer is not responsible for the Winner's claims related to the expectations of the T-Shirt Prize. The Winner is entitled to submit claims on his/her own behalf directly to the entities responsible for the creation of the T-Shirt (manufacturers of the T-Shirt).

5. The Organizer is not responsible for the claims of the Winner, as well as the Companion, related to the expectations regarding the selected match for which the Winner will receive the Ticket. The Winner, as well as the Accompanying Person, is entitled to submit complaints on their own behalf directly to the entities responsible for the implementation of the selected match.

6. The Winner, as well as the Accompanying Person, while attending the selected match, are obliged to behave culturally and in accordance with the rules of the stadium, according to the conditions of the selected match to comply with the regulations of the venue where the selected match will be held. In the event of any violation of the above, the Organizer reserves the right to immediately refuse further participation of the Winner, as well as the Accompanying Person, in the selected match. 

7. The Organizer shall not be liable in any way to the Winner, as well as to the Accompanying Person, for the Winner's inability to use the Ticket (e.g. participate in the selected match) as a result of the Winner's violation of the rules indicated in paragraph 6 above or other circumstances for which the Organizer is not responsible.

8. The winner of the contest is obliged to obtain the Companion's consent to provide his/her personal data, as referred to in § 5(9) of the Regulations, before providing them to the Contest Organizer.

9. The Winner shall be fully responsible for the accuracy of the Companion's data provided and declares that their transfer will be made only with the Companion's consent.

10. The Winner indemnifies the Organizer from any liability in case of any irregularities related to the transfer of personal data of the Companion.

11. In the event that claims are formulated against the Organizer for failure to obtain the Companion's consent to transfer his/her personal data, or any other irregularities related thereto, the Winner undertakes to provide all necessary explanations.

12. The Organizer shall have the right of recourse against the Winner in case of any negative consequences related to the transfer of personal data of the Companion.

13. The Organizer is not responsible for the inability to collect the Prize if the Participant fails to meet the deadlines specified in § 5 of the Regulations.

14. The Organizer does not provide any advice, recommendations, analysis or suggestions on investing on the Platforms. The Organizer is not the Participant's broker, intermediary, agent or advisor and has no fiduciary relationship or obligation to the Participant in connection with the Participant's entry into the Contest or other activities performed by the Participant on the Platforms in this regard.  The Organizer does not recommend buying, selling or owning any cryptocurrencies and informs that investing in cryptocurrencies involves a high degree of risk. There is a risk of losing invested funds due to changes in cryptocurrency exchange rates.

15. Any cryptocurrency marketing material related to the Contest has not been reviewed or approved by any competent authority in any member state of the European Union. The cryptocurrency offeror is solely responsible for the content of the cryptocurrency marketing material. The offering cryptoasset in the form of ZND Token is BB Trade Estonia OÜ, headquartered in Tallinn, Estonia, operator of the zondacrypto exchange available at https://zondacrypto.com/en/home. The cryptoasset offeror can be contacted at +372 56340552 or email address: [email protected]. An information document in the form of a whitepaper on the ZND Token has been published at: http://assets.znd.co/token/pl/whitepaper.

 

§ 8 

Contest Commission

1. The proper conduct of the Contest will be supervised by a Commission appointed by the Organizer, consisting of two persons selected by the Organizer (hereinafter: "Contest Commission" or "Commission").

2. The tasks of the Commission referred to in the preceding paragraph include, in particular:

   • checking whether a given Participant meets all the conditions for participation in the Contest;

   • selecting the Contest Winners;

   • awarding the Prizes for each place to the Winners;

   • handling Participant's complaints, in accordance with § 9 of the Regulations. 

 

§ 9 

Complaints

1. Complaints related to participation in the Contest, the Participant may submit:

1. by letter, to the address of zondacrypto's headquarters (Tähesaju tee 9, Tallinn, 13917, Estonia); or

2. by e-mail to: [email protected]; or

3. by filling out a model form: https://zondacrypto.com/en/helpdesk/contact-page.

2. Complaints should be submitted immediately after the occurrence of an event of concern to a Participant participating in the Contest, but no later than 14 days after the end of the Contest (for a complaint sent by registered mail, the postmark date is decisive).

3. The complaint should contain all information specified in the regulations found on the zondacrypto platform, available at https://zondacrypto.com/pl/legal/zonda-exchange, including in § 18 of the Regulations for the Provision of Services, in connection with the Complaint Procedure on the zondacrypto platform, available at: https://zondacrypto.com/documents/d/guest/complaint-procedure-en-docx.

4. The complaint procedure shall be conducted in accordance with the procedure contained in the regulations indicated in paragraph 3 of this section, including the Regulations on Provision of Services - § 18. Detailed rules for the complaint procedure can be found in a separate document referred to in the Regulations on Provision of Services - the Procedure for Filing Complaints on the zondacrypto Platform, available at: https://zondacrypto.com/documents/d/guest/complaint-procedure-en-docx. 

5. Complaints will be considered by the Organizer.

 

§ 10 

Personal Data 

1. The controller of the personal data is BB Trade Estonia OÜ with its registered office in Harju maakond, Tallinn, Lasnamäe linnaosa, Tähesaju tee 9, 1391 Estonia (office number 10), a company under Estonian law, registered in the Register of Entrepreneurs under number: 14814864 (hereinafter: "Data Controller").

2. The Data Controller processes personal data of Participants, Winners and Companions on the basis of: 

1. consent within the meaning of Article 6(1)(a) of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (hereinafter: "GDPR");

2. fulfillment of a legal obligation incumbent on the Data Controller within the meaning of Article 6(1)(c) of the GDPR in order to fulfill the obligation to keep accounting documents;

3. the Data Controller's legitimate interest in accordance with Article 6(1)(f) of the GDPR, consisting in particular of responding to any complaints, claims made as a result of this Contest.

3. All data obtained by the Contest Organizer on Contest Participants, Winners and Companions will be deleted or anonymized within 60 days, counting from the date the Contest ends or the Prize is sent to Contest Winners. 

4. The purpose of processing the Contest Participants' data is to properly organize the Contest and oversee its progress, as well as to be able to inform the Participants about the progress of the Contest, as well as to inform about the selection of the Winners and the awarding of the Prize in the Contest.  

5. The data of Participants, Winners and Companions will be deleted or anonymized in accordance with the preceding paragraph - with the exception of data that will be necessary to comply with legal obligations incumbent on the Data Controller and for the purpose of fulfilling the Data Controller's legitimate interest - necessary to process complaints or other forms of claims submitted by Participants, Winners or Companions, or other persons, as well as for the purposes of possible judicial or administrative proceedings.

6. Data shall be protected by technical and organizational measures to ensure an adequate level of protection, in accordance with applicable regulations.

7. The Data Controller processes only the personal data provided in the Contest. Personal data are not subject to automated decision-making for the purposes of the Contest. 

8. For the purposes of the Contest, personal data will be shared with companies affiliated by capital and personal links with the Data Controller, i.e. - Orion Software sp. z o. o. and Expofer Servis House s. r. o. and the operator of the ZND.co platform (ZND.CO OÜ). 

9. Contest participants and Companions have the right to:

1. the right to request from the Data Controller access to, rectification, erasure or restriction of processing of personal data concerning the data subject, and the right to object to processing, as well as the right to data portability;

2. file a complaint with the supervisory authority - Estonian Data Protection Inspectorate, 39 Tatari, 10134 Tallinn, Estonia, if the Participant or Companion believes that his/her personal data is being processed unlawfully. 

10. All requests, questions and demands related to data processing should be addressed to the Data Protection Supervisor appointed by the Data Controller: [email protected].

 

§ 11

Final Provisions

 

1. These Regulations are the only document defining the detailed rules of the Contest.

2. The Contest Organizer is entitled to change the content of the Regulations, both in part and in whole, at any time for reasons beyond the Contest Organizer's control, as well as when such change is made exclusively for the benefit of the Participants (including by adding additional prizes, extending the duration of the Contest and the possibility of granting the Contest Entry, facilitating the Participants' access to participate in the Contest and the possibility of obtaining a prize). Participants will be informed of any planned changes to the Regulations through an adequate communication channel, such as Social Media. 

3. Any changes to the Regulations will be effective from the moment they are published on the Organizer's website. 

4. The Regulations are available for the duration of the Contest on the Contest Organizer's website and at the Contest Organizer's office.

5. Any doubts concerning the terms, conditions and term of the Contest, the provisions of its Regulations and its interpretation shall be resolved by the Organizer. Such resolution of the Organizer does not deprive the complainant of the right to pursue claims under the rules of law.  

6. Any information about the Contest can be obtained by contacting the Organizer at e-mail address: [email protected].

7. In matters not regulated by these Regulations, the provisions of the Organizer's Regulations and generally applicable laws shall apply.

8. In case of conflict between the provisions of these Regulations and the provisions of the Organizer's Regulations, the provisions of these Regulations shall apply.

9. The Regulations, as amended, are effective as of July 23, 2025.