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promóció

Promotions and Prize Draws

Official page for active Cashletics promotions, prize draws and campaign rules.

Version: v1.11.1 Effective date: 2026-11-28

B BLOCK · FOR USERS

Promotional & Prize Rules

Lucky Wheel · Prize Draw with Entry Tickets · Physical Prizes

PR-001-EN

Data Controller Mózer Ferenc (sole trader)
Registered address 6044 Kecskemét, Hetény-Belsőnyír 268/2., Hungary
Tax number 41905517-1-23
Contact support@cashleticsapp.com
Effective date 28 November 2026
Prepared by Dr. Crespo Zsuzsanna | zsuzsanna@crespo.hu
Version v1.11.1
Governing law Hungarian law; gambling act: Hungarian Act XXXIV of 1991
Governing language Hungarian (PR-001). In case of any discrepancy between the Hungarian and English versions, the Hungarian version shall prevail.

cashleticsapp.com/legal.php · Campaign-specific rules template GDPR-compliant ✔

GOVERNING LANGUAGE NOTICE — PARTICULARLY IMPORTANT FOR THIS DOCUMENT

This document is the English translation of the Hungarian Promotional & Prize Rules (PR-001).

The legal opinion on gambling law classification (Section 2) is based on Hungarian law.

In case of any discrepancy between the Hungarian and English versions, the Hungarian version shall prevail.

Hungarian version: cashleticsapp.com/legal.php?lang=hu

1. Legal Status of the CP System

1.1 Definition of CP (Cashletics Point)

The CP (Cashletics Point) used in the Cashletics application is a virtual, in-app point with the following characteristics:

Characteristic CP status
Monetary value None — CP has no market or monetary value whatsoever
Convertibility to cash No — CP cannot be converted into money, vouchers, or any cash equivalent in any form
Transferability No — CP cannot be transferred to other users, sold, or gifted
Scope of use CP can be redeemed only for Pro time on the user's own account. From 28 November 2026 it cannot be exchanged for entry tickets.
Ways to earn CP Recording a financial entry, completing a step-count challenge, daily login, rewards of the PiggyRun skill-based mini-game, exchanging Piggy Coins verified on the server, referrals (Terms of Use Section 8.4), optionally watching rewarded ads, daily Lucky Wheel. CP cannot be bought for money.
Expiry CP points have no general expiry. Any future change requires prior user notice and updated legal documents.

ℹ Summary

CP is a gamification and motivation tool.

CP is NOT money, NOT a cash equivalent, cannot be redeemed for any real value and, from 28 November 2026, not for entry tickets either.

Participation in a prize draw is based on entry tickets, which are given exclusively for free activities (Section 4.0).

1.2 Relationship between XP, coins and CP

Point type Function Counts for draw?
XP (experience points) Level and rank — gamification element No
Coins Visual reward; only medals and badges that do not relate to steps or health appear on the leaderboard No
CP (Cashletics Point) Pro time (own account only) No
Entry ticket Entry to the campaign Yes

CP can also be earned by completing the PiggyRun skill-based mini-game — the reward is based on the player's skill performance, under pre-announced conditions and server-side limits. Use of PiggyRun is voluntary and is not a condition of participation in the prize draw.

1.3 Piggy Coin and source protection

CP earned through the regular use of PiggyRun, and CP credited when exchanging Piggy Coins verified on the server, is the same as CP earned for free. Piggy Coins cannot be bought for money. Neither CP nor Piggy Coins can be used — directly or indirectly — for entry tickets.

2. Legal Opinion — Gambling Law Classification

⚠ GOVERNING LANGUAGE — THIS SECTION IS PARTICULARLY IMPORTANT

The legal opinion in this section is based on Hungarian law (Act XXXIV of 1991).

The authoritative legal analysis is in the Hungarian version (PR-001, Section 2).

This English summary is provided for information only.

In case of any discrepancy, the Hungarian version shall prevail.

2.1 Criteria for gambling classification under Hungarian law

Under Section 1(1) of Act XXXIV of 1991 (Gambling Act), gambling is a game in which the player, (1) in return for paying money or providing something of monetary value, (2) depending on chance, (3) becomes entitled to a cash prize or another prize of monetary value.

The Gambling Act only applies if all three conditions are met simultaneously. The analysis below demonstrates that the Cashletics promotional system does NOT meet these conditions cumulatively.

2.2 Condition 1 — Paying money or providing something of monetary value

"Paid participation" under the Gambling Act means that a player may only participate in exchange for money or equivalent consideration.

In the case of Cashletics:

  • Entry tickets are given exclusively for the free, intended use of the app (Section 4.0): for regular opening and for completing the tutorial. Payment, a purchased product, a Pro subscription or CP does not lead to a ticket, either directly or through exchange.

  • The ways of earning CP and Piggy Coins (financial entries, step count, PiggyRun, ads) do not affect participation in the prize draw.

Key argument: participation in the prize draw requires an entry ticket, which is given to everyone on the same terms for free activity.

Watching ads, providing step data or payment does not speed up earning tickets.

Conclusion: condition 1 (paid participation) is not met.

2.3 Condition 3 — Prize of monetary value

The prize is a physical prize, which qualifies as a prize of monetary value. The classification is therefore based not on the nature of the prize but solely on the fact that participation does not involve paying money or providing anything of monetary value.

2.4 (No longer in effect from 28 November 2026)

2.5 Summary — legal classification

Gambling Act condition Met? Reason
Paying money or providing something of monetary value ❌ No Entry tickets are given for free activity
Chance ✔ Yes The draw is randomised
Prize of monetary value ✔ Yes Physical prize
All three together ❌ No The absence of the first condition excludes the Gambling Act

ℹ Legal position (approved by legal review — see PR-001 Section 2)

The Cashletics promotional system is NOT subject to the Hungarian Gambling Act.

No gambling licence is required.

This opinion applies to the current system design.

The classification must be reviewed if any way of earning tickets were linked to payment, a purchased product, a Pro subscription or ads, or if the prize value limit or the campaign mechanism changes materially.

2.6 Random reward packages (loot boxes)

Random reward packages (loot boxes). In the app, reward packages with random content (loot boxes) can be obtained exclusively free of charge — as a daily login streak reward or as a seasonal reward; loot boxes cannot be obtained for money or in any other way linked to a purchase. A loot box may only contain in-app virtual content: cosmetic items (skins, character elements), Piggy Coin or in-game items. A loot box contains no entry tickets. The rarity categories of the contents and a description of the opening odds are published by the Provider within the app. Opening a loot box cannot be tied to any monetary consideration; its contents are not money, not a cash equivalent and cannot be redeemed for cash.

Obtaining and opening a loot box cannot be tied to monetary consideration in any form, so the “stake” element of the statutory definition of gambling is absent; the random element alone — without consideration — does not create a licensing obligation.

3. Daily Lucky Wheel — Mechanism and Legal Classification

3.1 How the lucky wheel works

Element Description
Availability A daily base spin for every user, free of charge. Pro gives no additional spins, and neither do ads.
Participation requirement None — no entry ticket is needed for the Lucky Wheel.
Possible prizes CP or XP (base reward 5, 10 or 25 CP, or 5, 10 or 25 XP) — exclusively a virtual in-app reward. Entry tickets cannot be won.
Physical prize possible? No — no physical prize can be won on the lucky wheel
Cash prize possible? No — no cash can be won
Result determination Server-side random number generator (Cloud Functions) — result is not predictable in advance

3.2 Legal classification — lucky wheel

The daily lucky wheel is also outside the scope of the Gambling Act because:

  • Participation is free — no paid participation.

  • The prize is exclusively CP or XP, a virtual in-app point — not cash or a cash equivalent.

  • Virtual points have no market value and cannot be converted to cash.

ℹ Legal classification: the daily lucky wheel is a gamification motivation feature

that does NOT qualify as gambling under Hungarian Act XXXIV of 1991.

No gambling licence is required.

4. Physical Prize Draw — Participation Rules

4.0 Earning entry tickets

Entry tickets are given exclusively for the four free activities listed in Section 8.3 of the Terms of Use: seven days of Cashletics in a week, seven days of PiggyRun in a week, 15 active days in a month (opening Cashletics or PiggyRun) and the first completion of the tutorial. For the 15 days in a month, a day counts if the user opens Cashletics or PiggyRun on that Budapest calendar day; for the weekly tickets, opening the named app counts. From 28 November 2026 the app issues only standard entry tickets. Earning tickets does not depend on step data, health permissions, financial entries, ads, payment or a Pro subscription, and it is the same for every user. The Lucky Wheel, ads, referrals, the shop, chests, Pro and CP give no entry tickets. A new ticket source (for example levelling up) may only be introduced by amending these Rules and with notice under Section 14 of the Terms of Use. The start date of ticket earning is governed by Section 8.3 of the Terms of Use.

4.1 Draw mechanism

Element Description
Draw frequency to be determined per campaign
Participation requirement Entry ticket (Section 4.0).
How to participate Not automatic. The user actively enters a campaign with entry tickets.
Winner selection Random draw from eligible participants (Cloud Functions server-side random number)
Prize Electronic product — specific prize to be determined per campaign
Prize value HUF 50,000 – 500,000 (approx. EUR 130 – 1,300) to be determined per campaign
Use of tickets The number of tickets used for an entry and what happens to the tickets after the entry are set out in the campaign announcement.
Notification method support@cashleticsapp.com email (in-app push notification only once FCM is activated — FCM is currently not active)

4.2 Winner notification and prize delivery

  • The winner is notified by email on the day of the draw (and, once FCM is activated, also by in-app push notification).

  • The winner must confirm acceptance of the prize within 15 days by emailing support@cashleticsapp.com; the name and postal address required for delivery must be provided in this confirmation email (data processing: Section 7).

  • If the winner does not respond within 15 days, the prize lapses and a new draw may be held.

  • Prize delivery is by post or in person — shipping costs: to be determined per campaign.

  • The Organiser (Mózer Ferenc) shall fulfil all personal income tax obligations arising from the prize under Hungarian tax law (Act CXVII of 1995, Section 76). In the Organiser's view, on this basis the prize is free of personal tax liability for the winner, who has no separate tax declaration obligation in respect of the prize. The Organiser shall confirm the above tax classification with a tax adviser's opinion before launching the promotion. Upon delivery of the prize, the Organiser shall provide the winner with a tax certificate stating the legal title, HUF value of the prize and the amount of personal income tax withheld. Non-Hungarian residents should consult their local tax adviser regarding any applicable tax obligations in their jurisdiction.

4.3 Types of entry tickets and their per-campaign use

Types of entry tickets. From 28 November 2026 the app issues only standard entry tickets. Standard tickets cannot be converted into silver or gold tickets. A campaign accepts standard, silver and gold tickets obtained before 28 November 2026 only if its terms expressly allow earlier tickets and the given ticket type. Earlier ticket types are not weighting multipliers within the same draw: the campaign terms determine which type can be used in which prize-category draw. The odds per ticket (participation unit) and the campaign-specific conditions are published in the app before the campaign starts; no campaign starts without this publication.

Per-campaign ticket type. The Provider determines per campaign which ticket type(s) may be used in a given draw. This is included in the in-app publication of the campaign, and the system verifies server-side that only the ticket type(s) authorised for the given campaign can be used.

4.4 Excluded Persons, Manual Crediting and Integrity of the Draw

Excluded persons. The Service Provider may not take part in the draw, nor may any natural person holding access of any level to the administration interface of the application — including the controller, the developer acting as processor, and any further person listed in the access matrix in clause 2.1 of SZ-001 — nor the close relatives of such persons within the meaning of Section 8:1(1) point 1 of the Hungarian Civil Code. The exclusion applies even where, at the time of the draw, the access consists solely of a temporary entitlement granted for pre-release testing (DPA-003, clause 3.9.6).

Manual crediting. The manual crediting of XP, CP, coins, Piggy Coin, items, loot boxes or any other value may take place solely with the Data Controller's prior, written and traceable approval, with mandatory justification. Every manual crediting is recorded in the administrator audit log (ROPA-001, item 17): the designation of the operation, the justification, the identifier and role of the acting administrator, the identifier of the user concerned, the previous and the new value, and the timestamp.

Integrity of the draw. Manual crediting may not be used to confer an unjustified advantage on any participant in the draw. Where a manual crediting directly or indirectly affects the number of entry tickets or eligibility for the draw, this shall be expressly recorded in the approval. The draw is conducted by server-side random number generation (Cloud Functions), which cannot be influenced through administrator rights.

Daily lucky wheel. The daily lucky wheel described in clause 3 falls within the scope of these rules; the related server-side record (daily_spin) is subject to the same controls.

5. Ads and Entry Tickets — No Link

5.1 Rewarded ad mechanism

Element Description
Ad type Google AdMob rewarded video ad
Display Optional — the user decides whether to watch an ad
CP reward 5 CP for each verified, fully watched ad.
Limit No cap; given once for the same view, on the basis of the ad provider's authentic verification. No XP, no spin of the wheel and no entry tickets.
Is it mandatory? No — watching an ad is never a condition for anything
PRO users PRO subscribers do not see ads — ad CP cannot be earned by PRO users

5.2 Logical chain — why this is not paid participation

  1. For watching an ad the user receives CP, which from 28 November 2026 cannot be exchanged for entry tickets. Entry tickets are given exclusively for the activities under Section 4.0. There is therefore no direct or indirect link between ads and participation in the prize draw. The discounted PiggyRun programmes (Terms of Use Section 8.2) give no entry tickets.

6. Physical Prize — Type, Value and Campaign

6.1 Prize characteristics

Characteristic Description
Prize type Electronic product (e.g. smartphone, headphones, smartwatch, tablet)
Prize value HUF 50,000 – 500,000 gross retail value (approx. EUR 130 – 1,300) to be determined per campaign
Redeemable for cash? No — the item is delivered; its monetary equivalent is not paid out
Substitutable? Exceptionally yes — solely in the event of an objective, unforeseeable procurement or distribution obstacle, with a prize of at least the same gross retail value and, where possible, of the same nature or a higher category. Substitution may not operate to the detriment of the participant or the winner.
Changes per campaign? Yes — the specific prize for each draw is announced in-app before the campaign begins

6.2 Campaign announcement procedure

  • Before each draw campaign begins, the app publishes the draw date, exact prize description and value, the entry ticket type(s) usable in the given campaign, entry ticket redemption/use conditions, and the rule that entry tickets are given exclusively for the free activities under Section 4.0.

  • Campaign terms cannot be modified after announcement.

  • The publication location of previous campaign data and winners is determined per campaign (e.g. in the app’s “Winners” section).

7. Data Processing in Connection with Prize Draws

7.1 Categories of data processed

Data category Purpose Legal basis Retention
Username, number and origin of entry tickets (source, time) Eligibility verification GDPR Art. 6(1)(b) — contract performance For the lifetime of the account
Opening days (the Budapest calendar day on which Cashletics and PiggyRun were opened, the day of last activity) Determining the weekly and monthly ticket GDPR Art. 6(1)(b) Until the first activity after the end of the weekly or monthly period, at the latest until the account is deleted. By 31 January 2027 at the latest, the Service Provider will introduce automatic deletion, which deletes the days no later than 3 months after the end of the calendar month.
Record of the ticket issued (identifier of the period, the source event and the rule version; without the list of opening days); the fact of first completing the tutorial Proving lawful issue of the ticket, excluding double crediting GDPR Art. 6(1)(b) For the lifetime of the ticket or the account; if the ticket took part in a draw, together with the draw records for 5 years
Draw participation record Draw documentation GDPR Art. 6(1)(b) 5 years (legal claims)
Winner identification (user ID) Prize delivery GDPR Art. 6(1)(b) 5 years (legal claims)
Winner name, postal address Prize shipment GDPR Art. 6(1)(b) Delivery + 1 year
Tax documentation data (if required) Tax compliance obligation GDPR Art. 6(1)(c) — legal obligation 8 years (accounting law)

7.2 Firestore data structure reference

The Firestore prize draw data structure is defined in PR-001 (Hungarian version), Section 7.2.

Collection path: promotions/{campaignId}/entries/{userId}

Key fields: user_id | tickets_used | entry_time | is_winner | prize_sent | notified_at

For full field definitions, refer to PR-001 Section 7.2.

7.3 Data subject rights in connection with prize draws

  • A deletion request may be submitted at any time. The data required for delivering the prize (name, postal address) cannot be deleted until delivery, as the processing is necessary for the performance of the contract (GDPR Article 17(3)(b)), and the data of the accounting document until the end of the retention period under the Hungarian Accounting Act; this does not prevent the deletion of the other data.

  • The record of draw participation (in pseudonymised form) cannot be deleted — required for legal claims.

  • Data processing requests: privacy@cashleticsapp.com

8. Governing Law and Dispute Resolution

These rules are governed by Hungarian law. In the event of disputes arising from the interpretation or application of these rules — if the parties cannot reach an out-of-court settlement — the exclusive jurisdiction of Hungarian courts applies.

Legal source Scope
Hungarian Act XXXIV of 1991 (Gambling Act) Gambling regulation — NOT applicable to the promotions under these rules (see Section 2)
Hungarian Civil Code (Act V of 2013) Prize draw as a civil law relationship
GDPR (EU) 2016/679 Data processing conditions — see Section 7
Hungarian Act XLVII of 2008 (Unfair Commercial Practices) Prohibition of unfair commercial practices — the promotion is not misleading
Hungarian Act CXVII of 1995 (Personal Income Tax Act) Personal income tax on physical prizes — see Section 4

Users wishing to submit a consumer complaint may contact the Hungarian National Consumer Protection Authority (nfh.hu) or the consumer protection office of their local district authority. Users outside Hungary may contact the relevant consumer protection authority in their country of residence.

9. Transitional Provisions for the Amendment of 28 November 2026

9.1 CP earned before 28 November 2026 is kept and, from the effective date, can be redeemed for Pro time on the user's own account.

9.2 CP earned for free — including CP earned for rewarded ads — can be exchanged for entry tickets until 23:59 (Budapest time) on 27 November 2026 at the latest. Purchased CP cannot be exchanged for entry tickets.

9.3 Entry tickets obtained before 28 November 2026 — irrespective of their origin, including those obtained from the Lucky Wheel and from Pro time obtained with CP — remain valid and can be used in campaigns announced after the effective date under the terms of each campaign, in accordance with Section 4.3. From 28 November 2026, standard tickets cannot be converted into silver or gold tickets. Whether an earlier ticket can be used in a campaign is determined by the terms of that campaign; we cannot guarantee this in advance. CP you keep can be used for Pro time.

9.4 Entries submitted before 28 November 2026 will be drawn under the rules in force at that time.

9.5 Pro time obtained with CP runs until it expires, but from 28 November 2026 it gives no extra spin of the Lucky Wheel and no entry tickets.

9.6 Had any purchase been made before the sale of CP packs was stopped on 5 November 2026, the Service Provider would settle it individually, without disadvantage to the user. (According to the Google Play report, there were no paid orders until 5 November 2026.)

9.7 No prize draw campaign will start on or before 28 November 2026.

10. Governing Language and Version Control

GOVERNING LANGUAGE

This document is an English translation provided for the convenience of non-Hungarian speaking users.

The authoritative version of these rules — including the legal opinion in Section 2 — is the Hungarian

language document PR-001. In case of any discrepancy between the Hungarian and English versions,

the Hungarian version shall prevail.

Hungarian version: cashleticsapp.com/legal.php?lang=hu

Version Date Changes Approved by
v1.5 1 August 2026 Initial version Dr. Crespo Zsuzsanna
v1.7 1 August 2026 Sybell registered address corrected (DPA-001); DPA-002 clause 3.6 breach notification narrowed + non-excludable liability categories; DPA-003 liability cap (12 months’ fees, min. HUF 500,000); publication date updated Dr. Crespo Zsuzsanna
v1.8 1 August 2026 Legal review approved (DPIA-001, LIA-001, PR-001; DPA-002 clause 3.6 + liability framework; DPA-003 liability cap). Signatures pending. Dr. Crespo Zsuzsanna
v1.9 1 August 2026 PiggyRun mini-game, Piggy Coin, entry ticket types (standard/silver/gold) and random reward packages (loot boxes) regulated; loot box gambling-law classification approved; gamification data elements extended (AT-001, ROPA-001); DPA-001 AdMob/Firebase acceptance dates; DPIA-001 I4 closed. Dr. Crespo Zsuzsanna
v1.9.1 1 August 2026 Sybell (DPA-002): instead of signing the draft agreement, Section 11.1 of Sybell’s GTC (20 July 2026, Art. 28(3) and (9) GDPR) governs the processing; references updated; GTC archived. Dr. Crespo Zsuzsanna
v1.10 1 August 2026 DPA-003 (Balázs Bánki): implementation of the developer comments — narrowing of the developer role and data categories, incident notification under Art. 33(2) GDPR, notification of unlawful instructions under Art. 28(3) GDPR, clarification of third-country transfers, deletion of the minimum liability floor. Addition of administrator feature switches and audit log (ROPA-001 row 17, 12-month retention); clarification of the admin interface access matrix (SZ-001 2.1). [külön nem került jóváhagyásra — a v1.10.1 váltotta fel]
v1.10.1 6 August 2026 · suppl. 4 September 2026 and 5 September 2026 EN terminology alignment (Article, Data Controller); implementation of the legal review decisions; data categories of the four undocumented collections in Section 4 of AT-001. Supplement of 4 September 2026: placeholder instead of a pre-filled signature date in unsigned copies (14 documents); GDPR Article 12(3) “without undue delay” wording implemented (AT-001 HU/EN, EJ-001); in DPIA-001 the retention of health data after withdrawal changed from 7 to 30 days, aligned with HE-001; corrected EU-US Data Privacy Framework reference in the English version of BH-001; in DPA-002 the processing relationship recorded as based on Section 11.1 of the Sybell GTC and the Controller's written instruction instead of a signature; column misalignment corrected in the Article 28 record of DPA-001. In addition: in ROPA-001 and ATJ-001 the number of recorded processing activities corrected to the actual 25 (previously 17 and 16 respectively); in the consent examples of HJ-001 the reference to the never-published AT-001 v1.8.3 corrected to the published v1.8. Implementation of the legal review decisions (4 September 2026): the assistance obligation under GDPR Article 28(3)(f) added as clause 3.7 of DPA-002 and clause 3.10 of DPA-003; in the Play Data Safety table of GPS-001, transfers to Firebase Analytics are no longer declared as sharing — consistent with the document's own conceptual distinction — and health and fitness data are no longer declared as required; Firebase Analytics (L1) and the aggregated analysis built on it (L3) removed from the scope of LIA-001, as their legal basis is consent, with the exclusion table extended accordingly; the incorrect reference to the Hungarian Infotv. removed from the age-limit reasoning of KK-001, together with the identical wording in GPS-001 and XHV-001; the response deadline in EJ-001 aligned with the public undertaking in AT-001 (60 days in total at most); an explanatory note added to the 30-day undertaking under Article 12(3); the Hungarian version of BH-001 supplemented with the description of third-country transfers; AT-001 now states the storage location of Cloud Firestore as the eur3 European multi-region, consistent with ROPA-001; the developer added to the list of processors in AT-001, and the instruction clause of DPA-003 extended with the transfer wording; in six places the term “anonymised” refined to “pseudonymised”. Based on the Controller's statement of 4 September 2026: two-factor authentication for the admin interface is recorded with its actual completion date (1 September 2026) instead of an expired deadline; the emergency shutdown access issued in the developer's name has not yet been activated, therefore the access matrix of SZ-001 and the transitional provision in clause 3.9.8 of DPA-003 record the current and the final state separately, listing the data actually accessible through that role; the revocation of the earlier project-level (Editor) permission is recorded. The data subject branch of INC-001 received the exemption grounds under GDPR Article 34(3), the retention period of ROPA item 06 was aligned with AT-001, an expired external reference was replaced, and header-row repetition was enabled for two multi-page tables in SZ-001. The duplicate logo on the first page — already present in the header — has been removed from the document body (29 documents); the header logo is unchanged and no document text was altered. Supplement of 5 September 2026: the erroneous Gambling Act reference removed from the tax certificate clause in Section 4; the Personal Income Tax Act added to the table of legal sources; "unconditional" deleted in Section 3; the tax classification supplemented with confirmation by a tax adviser; the legal reservation in Section 2 converted into a review clause following legal approval; the package-level legal approval recorded in the version table. Supplement of 6 September 2026: based on the Controller's reply of 5 September 2026, the effective date of the package was changed from 1 August 2026 to 1 October 2026 (79 places; the applicability wording of DPA-003, the approval dates in D2-UGY and the dates in the version tables were deliberately left unchanged); the prize value and prize substitution confirmation requests closed on the basis of the Controller's statement; in the draw participation record „anonymised” refined to „pseudonymised”. Supplement of 6 September 2026 following the external quality review (P2), 37 confirmed findings: the winner is notified by email; push notification only once FCM is activated. Following the P3–P5 external reviews (operability · data-subject perspective · adversarial) of 6 September 2026: the channel for collecting delivery details (the confirmation email). Based on the controller's partial status letter of 7 September 2026 and the signed DPA-003 (11 September 2026): Section 4.3 now states that ticket types are prize categories, not weighting multipliers; deduction of converted standard tickets; publication of odds before the campaign. Supplement of 16 September 2026 (legal reviewer's decision 2 of 15 September 2026, option „B”): in the tax classification of Section 4, the categorical statement on the winner's tax exemption was also converted into conditional form („in the Organiser's view”); confirmation by a tax adviser remains a condition of launching the promotion. Second supplement of 16 September 2026 (legal reviewer's decisions 3, 4, 6 and 9 of 15 September 2026): banking notification split into two steps in ROPA item 06 (reading/processing under Art. 6(1)(a) with immediate deletion; the approved entry falls under item 03, Art. 6(1)(b)); prize draw data categories and retention periods in Section 4 of AT-001 (HU/EN) and ROPA item 10 aligned with Section 8 of PR-001 (four retention periods, accounting document under Art. 6(1)(c)); the deletion sentence of PR-001 converted into conditional form referring to GDPR Article 17(3)(b); the effective-date cell of PR-001 reads „1 October 2026”; the profile data row split (language/currency/theme under Art. 6(1)(b) · country/age/gender under Art. 6(1)(a), optional). Supplement of 24 September 2026: the effective date of the package changed from 1 October 2026 to 12 OCTOBER 2026. Reason: under Section 14 of ASZF-001 and Section 9 of AT-001, users must be notified of changes at least 15 days before the effective date; publication and notification took place on 27 September 2026 (instead of the previously planned 25 September). The signature date of KK-001 and PR-001 is the day of publication. Dr. Crespo Zsuzsanna
v1.11 11 November 2026 New rewards model (1.0.79), effective 28 November 2026: entry tickets are given exclusively for free activity (4.0); CP cannot be exchanged for entry tickets (1.1–1.3); the legal classification in Section 2 rests on a single pillar, free participation (2.1–2.5; 2.4 no longer in effect); chests contain no tickets (2.6); the Lucky Wheel awards CP, tickets cannot be won (3.1); entry with entry tickets, one kind of ticket (4.1, 4.3); no link between ads and entry tickets (5); opening days and ticket record (7.1); transitional provisions (new 9); governing language and version control is Section 10. Dr. Crespo Zsuzsanna
v1.11.1 11 November 2026 Clarification before entry into force (based on the controller's information of 11 November 2026), effective 28 November 2026: CP can be redeemed only for Pro time on the user's own account (1.1, 1.2, 9.1); the Lucky Wheel awards CP or XP (3.1, 3.2); the app release version is 1.0.83 (instead of 1.0.79 in the v1.11 row). Dr. Crespo Zsuzsanna

Signatures

Data Controller

....................................................

Mózer Ferenc

Date: 27 September 2026

Legal Reviewer

....................................................

Dr. Crespo Zsuzsanna

Date: [upon approval]

Next scheduled review: 1 August 2027, or per campaign

This document is a campaign-specific promotional/prize rules template. It does not constitute the final rules of an announced prize draw by itself. Before each campaign starts, campaign-specific fields must be completed, approved and published.

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